Incident to Billing or Incident to Service

April 10th, 2009 - Jeannie Cagle, BSN RN CPC
Categories:   Billing   Coding   Evaluation & Management (E/M)   Medicare  
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By Jeannie Cagle, BSN, RN, CPC

This question appeared in a recent list serve. My two responses are based upon two different assumptions: (1) both providers are physicians, and (2) one of the providers is not a physician. The principal points are that each physician has a unique National Provider Identifier (NPI), and a physician must be on site when a non-physician provider extends services under his or her NPI.
Question:
Regarding incident to billing or incident to service, is there ever an occasion where, let's say, Provider A is out of the office and Provider B is in the office.  Provider B sees Provider A's patient and bills the visit under Provider A.
Answer:
If there are only two providers in this practice and both are physicians, Provider B cannot ever bill under providers A’s NPI.  Each physician must use his or her own NPI.
If Provider A is a physician and Provider B is a Nurse Practitioner or Physician Assistant, and no other providers are in the practice, Provider B cannot bill under provider A’s NPI because Provider A is not in the suite when the visit takes place.
If you have a question that needs an answer, please contact me at jcagle@cokergroup.com.

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