I would have to disagree that the removal of an IUD qualifies as "incident to" service. The full example in this link states "Examples of qualifying “incident to” services include cardiac rehabilitation, providing non-self administrable drugs and other biologicals, and supplies usually furnished by the physician in the course of performing his/her services (for example, gauze, ointments, bandages, and oxygen)." In no way would the removal fall into this example category. If the insurer does not allow direct billing by the NNP and their policy states that it can be billed by the supervising MD, then bill away. Otherwise I think this practice may be in trouble during an audit.
That is not how I am interpreting the document. I will check for additional references. Some excerpts:
“Incident to” services are defined as those services that are furnished incident to physician professional services in the physician’s office (whether located in a separate office suite or within an institution) or in a patient’s home.
To qualify as “incident to,” services must be part of your patient’s normal course of treatment, during which a physician personally performed an initial service and remains actively involved in the course of treatment. You do not have to be physically present in the patient’s treatment room while these services are provided, but you must provide direct supervision, that is, you must be present in the office suite to render assistance, if necessary. The patient record should document the essential requirements for incident to service.
More specifically, these services must be all of the following:
• An integral part of the patient’s treatment course;
• Commonly rendered without charge (included in your physician’s bills
• Of a type commonly furnished in a physician’s office or clinic (not in an institutional setting); and
• An expense to you.
An IUD removal (if already determined to be the treatment plan by physician) meets all 4 of those.
