Wiki Definition of Supervising MD when it comes to incident to

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nancy726

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i am looking for a hard definition of supervision physician as it applies to "incident to". If there are multiple physicians in the office at the time of service, who is the service billed under? should it be the physician on the schedule seeing patients or can it be a physician in the office doing administrative work? i have a number of physicians questioning this and i was just looking for some clarification if possible thank you,
 
For 'incident to' purposes, the only 'hard' definition is that the supervising physician must be present in the office and available to provide assistance if needed. If there are multiple physicians that meet this definition at a given time, then it's really up to you to select one for billing purposes. My suggestion would be to select the physician who is most involved in that particular patient's care at the visit, or the one who wrote the care plan that the NPP is following at that visit. As long as the visit is supervised and meets all of the other 'incident to' requirements, Medicare isn't going to be concerned about which physician you use since the payment is going to the practice and not to the individual MD, and it's not going to change the payment amount.
 
Agree as above. It is detailed here: Medicare Benefit Policy Manual, Chapter 15, Section 60.

See: https://www.aapc.com/blog/44912-seven-incident-to-billing-requirements/ (keep in mind this article is from 2018).

I would add, behind the scenes, depending on how the physicians are paid and RVUs, some providers don't like it when a different supervising is used if they employ their NPP. I have seen where if one PA exclusively works with one provider, that supervising MD does not want anyone else getting the "credit" in the billing system in a large group. This depends on what kind of group you are with, physician expectations and practice policy. Managers, revenue cycle, compliance and execs (such as the CFO) should be involved in decisions about inciden-to if your practice has never billed that way before. The practice management system would also need to be reviewed to make sure configurations are correct. It's a high risk area.
 
klapetri@ilovemygyn.com said:
can someone explain in simple terms- incident to billing vs. split shared services?
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I saw your other similar question in another post too. It looks like you're trying to find out the difference between split-shared visits and incident-to.

One of the key differences in very, very oversimplified terms:

With Split-Shared, both the NPP and the doctor are seeing/treating the patient. The service will be billed under the provider who performed the substantive portion of the visit. (Ex - If 51% of the visit was done by the NPP and 49% by the MD, it's billed under the NPP.)

With Incident-To, the NPP treats the patient following a treatment plan previously established by the physician. The physician doesn't treat the patient that day. (A supervising physician needs to be present in the office, but they don't have to be in the room.)


If you're going to bill Split-Shared or Incident-To, you'll need to understand all the complexities and requirements involved with whichever service you bill. However, I think you were just trying to figure out the difference on a very basic level, so that's how I answered the question.
 
thanks for your reply.
split/shared services pos can not be in office?
Incident to and spilt/shared services can be with physician assistant and nurse practitioner ? or only nurse practitioners?
what commercial payors in NY follow incident to services?
 
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