Incident To

ucgsb1

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Practice I work for is bringing on a provider (MD) who is licensed in New York moving to Illinois. As we await credentialing, we were looking to bill incident to for this MD under the attending (IVF Clinic) .

We understand the rules for the E+M and treatment plans to be managed by the attending , but I can not find rules for out of state license. Do we need to wait for an Illinois license to be in place prior to billing incident to or does Locum Tenens rules apply. I'd appreciate any leads or experienced advice.
 

CodingKing

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Practice I work for is bringing on a provider (MD) who is licensed in New York moving to Illinois. As we await credentialing, we were looking to bill incident to for this MD under the attending (IVF Clinic) .

We understand the rules for the E+M and treatment plans to be managed by the attending , but I can not find rules for out of state license. Do we need to wait for an Illinois license to be in place prior to billing incident to or does Locum Tenens rules apply. I'd appreciate any leads or experienced advice.
MD to MD is not eligible for incident to. That is for mid-levels
 

thomas7331

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Physicians cannot practice in a state without being licensed first, so they will not be able to see patients at all until licensed. Licensing and credentialing are two different things, though - once the MD has a license, they can legally see patients, but you may not be able to get payment depending on specific payer enrollment requirements.

Billing the new provider's services under a different provider to obtain payment while you wait for enrollment is problematic and ill-advised. The provider can only bill as a locum if they are replacing a provider who is absent or on leave from the practice. 'Incident to' is a little trickier and as the previous post states, this is normally an arrangement for mid-levels. For a physician to bill as 'incident to', they would have to be practicing completing under the supervision of the other physician, executing an established care plan for existing patients with no new problems and not making any independent medical decisions. This isn't recommended for physicians because they aren't trained to practice this way and you could be setting yourself up for compliance problems. The safest practice, in my experience and opinion, is to wait until enrollment is completed before scheduling patients with that provider.
 

Coder2468

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I also do not think an MD can bill incident-to another MD. I've done a fair amount of research on incident-to guidelines in the past few months because my practice recently brought on a mid-level for the first time. I have not come across anything stating MDs can bill under other MDs this way. Also, not all insurance carriers follow incident-to guidelines and allow it. For example, our local BCBS does not allow it at all.

Personally, I think you should steer your practice away from allowing the new dr to see patients until he is credentialed with the payers. And licensing is a whole different thing - he can't see patients without being licensed.

I also just noticed you are in Illinois. I am in Illinois as well (Kane County), and our BCBS provider advocate was very clear that BCBS of IL doesn't recognize incident-to at all.
 
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