The NPBusiness Show with Barbara C Phillips, NP

The NPBusiness Show is all about knowledge equaling success. All NPs, all healthcare providers need to understand the basics of business in order to be successful. But that’s not all. We need news, strategies, professional and personal development and the permission to self care. Your host Barbara C Phillips, MN, GNP-BC, FNP-BC, FAANP is a entrepreneur, business coach, speaker, blogger and strives to be a bit geeky. She and her guest discuss questions and issues pertaining to the clinical and non-clinical entrepreneur as well as the employed nurse practitioner. The NPBusiness Show is a continuation of the SAGEClinician podcast with a business twist. Show notes and further information is at NPBusiness.ORG/podcast.
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Nov 11, 2015

Does the idea of Incident To billing leave you perplexed? Are you working with individuals who insist that all your visited be billed out as incident-to? Well, this is what we are going to talk about today on the NPBusiness Show podcast.


  • NPWeek Webinars continue. The 3rd one is this week, Sunday, Nov 15, 2015. More details here.
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Incident-To Billing

Incident-to billing can be confusing. Many NPs find their employers wanting to do a lot of incident-to billing. The problem is it can potentially result in fraud charges if the rules are not followed.

Define (as per CMS): “Incident to” services are defined as those services that are furnished incident to physician professional services in the physician’s office (whether located in a separate office suite or within an institution) or in a patient’s home. These services are billed as Part B services to your carrier as if you personally provided them, and are paid under the physician fee schedule.

Allowable Discount: 15% to NPs and PAs. For example, if MD is allowed $100, NPs/PAs are allowed $85.


  • First of all the visit takes place in the office.
  • The physician must perform the initial service and continue to be actively involved in the course of treatment.
  • The NP or PA sees the patient in follow-up for the identified problem and follows the plan of care.
  • The physician MUST be in the office suite at the time the visit takes place, not necessarily in the exam room, but in the office incase “direct” supervision is required.
  • The documentation needs to reflect the essential requirements for an incident to services.
  • The NP or PA must be an employee or what medicare refers to as a “leased employee” or an “independent contractor” that is paid for by the physician and practice.


Note: “Incident to” services are also relevant to services supervised by certain non-physician practitioners such as physician assistants, nurse practitioners, clinical nurse specialists, nurse midwives, or clinical psychologists. These services are subject to the same requirements as physician-supervised services. Remember that “incident services” supervised by non-physician practitioners are reimbursed at 85 percent of the physician fee schedule. For clarity’s sake, this article will refer to “physician” services as inclusive of non-physician practitioners.
CMS Documentation: (shortened)

Your Turn

What's your experience with incident-to billing?