In the final Medicare physician fee schedule release on October 30, the Centers for Medicare & Medicaid Services (CMS) clarifies only the physician or practitioner who directly supervises incident-to services may bill for those services. However, the supervising physician does not need to be the provider who ordered or initiated the care. Medicare’s incident-to rules allow practices to bill the services of non-physician assistants under the supervising physician’s national provider identifier so the services are paid at 100% of allowable rate instead of 85%.
To bill incident-to, practices must follow specific rules such as:
- cannot do it for a new patient
- cannot do it for a new problem for an established patient
- supervising physician must be the one to bill for the service