Considerations for Billing “Incident-To" Correctly

For many healthcare practices, “incident-to” billing is a common strategy used to increase Medicare reimbursements.  It sounds like a smart revenue move. But without a clear understanding of the rules, it can also be a compliance landmine. 

The Centers for Medicare & Medicaid Services (CMS) have specific criteria that must be met for “incident-to” billing to be valid. These include requirements around supervision, patient status, and scope of service. Yet, many practices unintentionally cross the line—either due to misunderstandings or a lack of internal controls. When that happens, the financial impact of audits, repayments, or even False Claims Act penalties can far outweigh the revenue benefit. 

In recent years, federal enforcement actions have increased around improper “incident-to” billing, highlighting the need for tighter oversight. From billing under the wrong provider to not meeting supervision requirements, mistakes in this area are being scrutinized—and penalized. 

So what can compliance teams do? Start by ensuring your staff is trained on the nuances of incident-to rules. Implement regular audits to catch mistakes early. And make sure your documentation supports the billing decisions you make. 

To help you stay ahead of the risks, our upcoming webinar breaks down real-life enforcement examples, outlines the current CMS requirements, and offers practical strategies for auditing and monitoring “incident-to” billing practices. Don’t miss it.