Setting: In a physicians office. Can a nurse practitioner bill based upon counseling time? Under "incident to" rules billing under the physician number or when billing directly under their own number? We have found that NP cannot bill level 5 new or established patient codes directly under their own number. I don't know why, but I really have a block when it comes to NP's. Thank you for anyone who can help to put me back on the path of understanding.