You can't bill the services of one physician under a different physician's name or NPI. Period. That's flat out fraud, in every sense of the word. CMS is VERY strict about this. An exception would be locum tenens, but that's not applicable in your case. And it's obviously not a teaching facility, so there's no "Resident" "Supervising Physician" situation. And you are correct, you can't use incident-to either because the provider is not mid-level (PA, ARNP, etc). Incident-to only applies to NON-physician practitioners.
If you get audited, the documentation versus the billed charges won't match and that's not something you want to mess around with. That type of violation can nail the office with possible exemption from all government programs, fines, perhaps prison time if they want to be especially harsh, including YOU. If I were you, I'd flat out refuse to participate and avoid that at all costs.
https://www.cms.gov/Outreach-and-Edu...eet_905645.pdf
https://www.cms.gov/Outreach-and-Edu...ads/se0441.pdf
