Wiki mid levels and time - incident to

trinapitsch

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Hi,

i wans on a cenference call 12/4/12 with WPS and in that call we were told that a midlevel cannot bill incident to if they choose to ue time. This is due to the fact that since you are billing under the supervising providers NPI number the time spent would need to be the md/do. Did anyone else listen to this call? It's about 4 hours and i will go back and listen to it again, but i wanted to get confirmation that someone else has heard what i did. I"m not talking aobut a split/shared visit...i am talking aabout incident to. any advice or resources for clarification would be wonderful.

Thank you!
 
Here's some info that may help.

This article on The Ins and Outs of Incident-To Billing by Alice Gosfield on the American Acadamy of Family Physicians website features the following excerpt:
It’s also important to note that, when billing incident-to, nonphysician providers cannot be reimbursed for consultations or time-based E/M services when more than 50 percent of the service is counseling or coordination of care (according to the Carrier’s Manual, the only time that counts is face-to-face time between the physician and the patient in the office). However, certain nonphysician providers can be reimbursed for these services when billing on their own provider numbers. [See “On their own: Direct billing by nonphysician providers” on page 26 to find out how certain nonphysician providers can bill on their own provider numbers.]

You made clear that you were not talking about split/shared visits. In a split/shared visit, you can add the time together, and select the level of service based on the total time. Here is an Incident-To Decision Tree that may help.
 
Thank you for posting this article. I see that it from 2001 and it is not from CMS or a carrier. I have not seen my carrier (Noridian) publish anything regarding the NPP's ability to bill based upon time with incident-to. They are silent (so far) on the matter. While I do sometimes use societies, such as AAFP, for guidance, they are not the final say. I would encourage a thorough review of Medicare's I-to guidelines and your specific carrier's. If you heard the information from one of their webinars, ask them to show supporting documentation BEFORE they publish their Q&As. Sometimes they change their minds after researching off-the-cuff answers given during presentations.

Good luck!
 
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