Frequently Asked Questions

What are the requirements to bill ‘incident-to’ services?

The requirements to bill ‘incident-to’ services are:

1. The NPP is an employee, contracted employee or contractor of the physician/practice/entity billing for the services.
2. The patient is seen at doctor’s office/clinic setting (POS 11) and the supervising physician is present in suite.
3. The physician performs the initial patient visit, creates a care plan and is involved in subsequent services at a frequency that demonstrates active involvement in the patient’s care.
4. The NPP only provides established patient services. The supervising physician cannot bill ‘incident-to’ services provided by a NPP for a new patient or follow-up visits with an existing patient for a new problem(s).
5. NPP services rendered ‘incident-to’ a physician service are billed under the supervising physician’s National Provider Identification (NPI) number.
6. The NPP completes and signs the visit/service note. The supervising (billing) physician can sign the note if he/she chooses to.
7. Residents and fellows cannot supervise ‘incident-to’ services involving NPPs.

All these requirements have to be met in order to bill an NPP service as ‘incident-to’ under a supervising physician’s NPI for 100% reimbursement of the allowable Part B MPFS. Not meeting any one of these requirements will require the NPP to bill directly and receive only 85% of reimbursement of the allowable MPFS.