Wiki Incident-to and Time Based Billing

[Elliewl]

Prior to the 2021 E/M coding changes, when the advanced practitioners billed based on time where counseling and coordination of care dominated more than 50% of the encounter, they billed under their own NPI number. Per the Renal Physician Association conference in 2019, incident-to cannot be used for time-based codes. Under the 2021 E/M guidelines physicians and other qualified healthcare professionals can bill based on time or MDM. I was told during an AAPC workshop that the guidelines for incident- to have not changed. If an advanced practitioner selects the level of service based on time, can it be billed incident-to assuming the other requirements for incident-to have been met? I really appreciate any feedback.

 

[csperoni]

I don't recall that specific question on AMA or CMS guidance about the 2021 outpatient E/M changes.
I will also note that I would not consider E/M 99211-99205 "time based codes." It's definitely a grey area unless someone has a reference stating specifically one way or the other. Certainly the prolonged service codes are time based codes. I personally find that it's very rare in my practice for the time (under original or 2021) to be higher level than MDM.