Medicare Incident-To Billing Rules

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June 11, 2015

Question:
We have a new PA in our office and we want to make sure we are billing correctly when we bill for his services Incident-To the physician. Am I correct to assume that when a new Medicare patient is seen in our office that the physician has to see the patient, examine the patient, and develop the plan of care him or her, and, on the next visit, the PA can implement the plan of care and bill Incident-To assuming the physician or another supervising physician is in the office?

Answer:
Yes, to report services Incident-To (meaning implementing the plan of care and physician in the office), the physician must independently obtain the History of Present Illness, must independently perform the exam, and all the decision making components including ordering and reviewing of tests, making the diagnosis and determining the plan of care. Assuming the physician performs this work, the PA may implement (not change) the plan of care and report services Incident-To the physician if the physician or another supervising physician is in the office.
Incident-To services do not apply to the first visit for a new patient, established patient with a new problem, a visit where the PA changes the plan of care or when a physician is not in the office. Incident-To services also do not apply in the hospital setting.