Wiki Incident to billing

[lhoot]

Good Morning,
I'm hoping for some help with deciphering what documentation is required to determine what would be considered "incident to". I have a record that the PA did the history and exam and then signs that portion, the MD then does the impression and plan and signs his portion and also cosigns the whole visit. Would this constitute incident to billing? I'm thinking this would be a regular visit billed to the MD, since he is cosigning the whole visit and making the impression and plan of treatment.

Any and all advice will be humbly received.
Laura

 

[thomas7331]

Co-signing a note is note sufficient by itself to qualify a visit for 'incident to' billing - you have to look what services were performed and by whom. In order for any PA service to be billed under the MD, that service itself needs to be 'incident to'. That means that all of the services documented and performed by the PA must have been a part of a care plan created by the physician for the purpose of treating an established patient for an established problem. So in your example above, to bill this as 'incident to', the patient must be established with the MD, and the problem for which the PA did the history and exam must be a problem for which the MD had already personally evaluated the patient and created a care plan. If the patient is presenting with a new problem, then there should be documentation that the MD also conducted a face-to-face portion of the encounter to evaluate that problem, otherwise this would not qualify as 'incident to'.

I think the best way to think of 'incident to' is that it means that the mid-level provider is essentially acting a staff-member of the provider and executing a care plan on the provider's behalf - just following orders, so to speak. If the mid-level is acting as an independent provider themselves, diagnosing a new problem and deciding on a care plan, or making changes to an existing care plan, then this is no longer 'incident to', even if the supervising provider reviews and approves of the plan.

 

[lhoot]

Thomas,
Your explanation was awesome.

To sum up and make sure I'm understanding it fully, in order for this to be billed "incident to" there needs to be documentation on this visit with the mid-level provider stating that there was a previous visit with the MD, as well as, what the established plan of care was on that initial MD visit. As long as there are new new issues or no change in treatment and all other qualifications, i.e. MD in office at time of visit, etc, are met then this would be incident to. Without documentation of an initial visit and plan of care, then this goes to the mid-level provider.

Thank you for your time and experience,
Laura

 

[carolhodge]

Co-signing a note is note sufficient by itself to qualify a visit for 'incident to' billing - you have to look what services were performed and by whom. In order for any PA service to be billed under the MD, that service itself needs to be 'incident to'. That means that all of the services documented and performed by the PA must have been a part of a care plan created by the physician for the purpose of treating an established patient for an established problem. So in your example above, to bill this as 'incident to', the patient must be established with the MD, and the problem for which the PA did the history and exam must be a problem for which the MD had already personally evaluated the patient and created a care plan. If the patient is presenting with a new problem, then there should be documentation that the MD also conducted a face-to-face portion of the encounter to evaluate that problem, otherwise this would not qualify as 'incident to'.

I think the best way to think of 'incident to' is that it means that the mid-level provider is essentially acting a staff-member of the provider and executing a care plan on the provider's behalf - just following orders, so to speak. If the mid-level is acting as an independent provider themselves, diagnosing a new problem and deciding on a care plan, or making changes to an existing care plan, then this is no longer 'incident to', even if the supervising provider reviews and approves of the plan.

Thomas

I have been in this line of work for many years. Your above explanation of incident billing is by far the best and clearest I have come across. I am keeping it for future reference. Thank you

 

[CatchTheWind]

Me, too!