July 22, 2025 | Posted by :
Healthicity
Healthicity
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Thank you for attending our recent webinar on Incident-To Billing.
Below is a consolidated summary of key questions and answers from the session. This reference is designed to help you navigate the nuances of Incident-To billing rules, from supervision requirements to documentation best practices.
Some assumptions were made when the proposed question did not provide all necessary details. To obtain guidance for a specific situation, contact Healthicity’s advisory services.
Who May Perform Services Incident-To a Physician/NPP?
Q: Can RNs (or MAs) furnish nurse-visit-type services incident to?A: Yes. RNs, MAs, LPNs, techs, genetic counselors, etc., qualify as auxiliary personnel under direct supervision and within state scope. They don’t enroll in Medicare.
Q: Do NPs/PAs qualify?
A: Yes, they may bill services performed by auxiliary personnel incident-to under their own NPI.
Q: Does CMS recognize medical assistants?
A: Yes. CMS includes MAs as auxiliary personnel under incident-to.
Settings Where Incident-To Can / Cannot Be Used
Q: Physician office / urgent-care suite (POS 11 or 20)A: Yes, if all requirements are met. Urgent-care clinics billing PFS are treated like offices.
Q: Same-building / two-story clinic
A: Yes, as long as it's the same address and suite with supervising physician immediately available.
Q: Assisted-living / patient home
A: Potentially. It depends on the circumstances and services provided.
Q: FQHCs / RHCs
A: Not applicable. These are paid under all-inclusive PPS.
Q: Hospital outpatient departments
A: No. Incident-to does not apply in hospital outpatient settings.
Supervision Requirements
Q: Direct vs. general supervisionA: Most services require direct supervision. Some behavioral-health and care-management services allow general supervision.
Q: Virtual direct supervision
A: In many circumstances, two-way A/V supervision is allowed through CY 2025.
Q: Multiple locations / being 'immediately available'
A: Physicians must be able to intervene immediately. Keep a log.
Q: Group practices
A: Any physician/NPP under the same TIN may supervise.
Documentation & Signature
Q: How detailed must the plan of care be?A: Include diagnosis, treatment goals, and intent for follow-up by NPP or auxiliary personnel.
Q: Is a co-signature mandatory?
A: CMS does not require one, but check with your MAC.
Q: Recommended verbiage
A: Examples: 'incident to Dr. Smith’s plan dated 3/1/25', 'Dr. Smith on-site.'
Q: Proving active involvement
A: Use periodic physician touch-points and save supervision logs.
Billing Mechanics
Q: New vs. established patientsA: Incident-to never applies to new patients or new problems for which a plan of care has not already been developed.
Q: Rendering provider on the claim
A: When incident to rules are met, use supervising provider’s NPI for reimbursement.
Q: Scenario example
A: Established DM patient seen by NP incident-to a physician plan—bill under physician if all other incident-to rules are met.
Behavioral-Health and Care-Management Nuances
Q: Behavioral health and care-management servicesA: General supervision is allowed for many BH services. All other incident-to rules still apply.
Q: Psychotherapy codes
A: Bill psychotherapy unless MD documents a distinct E/M service. Keep in mind state licensing and scope of practice laws that only allow certain licensed personnel to perform psychotherapy.
Regulatory Citations and Where to Look Up 'General Supervision'
Q: Regulatory citations
A: 42 CFR § 410.26, Medicare Benefit Policy Manual Ch. 15, CY 2025 PFS Rule, and FQHC/RHC Manual Ch. 13.
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