Billing Incident to Services-Whose Number Should Be Used?

December 29th, 2015 - Seth Canterbury, CPC, ACS-EM
0 Votes - Sign in to vote or comment.

Should You Bill Incident to Services for a Medicare Patient Under The Number of the “Supervising Physician” or the “Ordering Physician”?
 
This issue was first clarified in the preamble of the 11/1/01 Federal Register (available here on p. 23 of the file, p. 55267 of the document):
 
Comment: Several commenters requested that we clarify and distinguish between the physician (or other practitioner) ordering the incident to service and the physician (or other practitioner) supervising the auxiliary personnel who perform the incident to service. They stated that confusion exists as to whose Medicare Part B billing number should be used on the claim form.
 
Response: Inherent in the definition of an incident to service is the requirement that the incident to service be furnished incident to a professional service of a physician (or other practitioner). When a claim is submitted to Medicare under the billing number of a physician (or other practitioner) for an incident to service, the physician is stating that he or she either performed the service or directly supervised the auxiliary personnel performing the service. Accordingly, the Medicare billing number of the ordering physician (or other practitioner) should not be used if that person did not directly supervise the auxiliary personnel. We added language to the supervision requirement set forth in § 410.26(b)(5) to reflect this clarification.
 
The language added to the federal regulation mentioned above (found on p. 2 here) was this:
 
(5) Services and supplies must be furnished under the direct supervision of the physician (or other practitioner). The physician (or other practitioner) directly supervising the auxiliary personnel need not be the same physician (or other practitioner) upon whose professional service the incident to service is based.
 
This clarification was manualized via Transmittal 148 (Change Request 3138) on 4/23/04. The field designations mentioned in that transmittal have since changed, so instead of quoting from that, here are relevant excerpts from the current [as of 10/16/09] manual (Claims Processing Manual, Chapter 26, Section 10.4 here):
 
Ordering physician - is a physician or, when appropriate, a non-physician practitioner who orders non-physician services for the patient.
 
When a service is incident to the service of a physician or non-physician practitioner, the name of the physician or non-physician practitioner who performs the initial service and orders the non-physician service must appear in item 17
 
Item 17b Form CMS-1500 – Enter the NPI of the referring/ordering physician listed in item 17. All physicians who order services or refer Medicare beneficiaries must report this data.
 
Item 24J - Enter the rendering provider’s PIN in the shaded portion. In the case of a service provided incident to the service of a physician or non-physician practitioner, when the person who ordered the service is not supervising, enter the PIN of the supervisor in the shaded portion.
 
Enter the rendering provider’s NPI number in the lower unshaded portion. In the case of a service provided incident to the service of a physician or non-physician practitioner, when the person who ordered the service is not supervising, enter the NPI of the supervisor in the lower unshaded portion.
 
Item 31 - Enter the signature of provider of service or supplier, or his/her representative, and either the 6-digit date (MM | DD | YY), 8-digit date (MM | DD | CCYY), or alpha-numeric date (e.g., January 1, 1998) the form was signed.
 
In the case of a service that is provided incident to the service of a physician or non-physician practitioner, when the ordering physician or non-physician practitioner is directly supervising the service as in 42 CFR 410.32, the signature of the ordering physician or non-physician practitioner shall be entered in item 31. When the ordering physician or non-physician practitioner is not supervising the service, then enter the signature of the physician or non-physician practitioner providing the direct supervision in item 31.
 
NOTE: This is a required field, however the claim can be processed if the following is true. If a physician, supplier, or authorized person's signature is missing, but the signature is on file; or if any authorization is attached to the claim or if the signature field has "Signature on File" and/or a computer generated signature. [All emphasis (in red) in the manual quote above was added.]
 
Based on the information above, the “rendering provider” (the person you bill under) for the later incident to service is the “supervising physician”—the one meeting the “direct supervision” requirement for the incident to service by being “in the office suite”, not the original “ordering physician”—the one initiating care but not “in the office” for the subsequent encounter. However, the ordering physician’s information must still be noted on the claim when it was a different provider from the one supervising the later incident to service.
 
Seth Canterbury, CPC, ACS-EM
Education Specialist
University of Florida Jacksonville Physicians, Inc.
Clinical Data Quality-Education Department
653 West Eight Street
Tower I, Suite 606
Jacksonville, FL 32209
(904) 244-9643

###

Questions, comments?

If you have questions or comments about this article please contact us.  Comments that provide additional related information may be added here by our Editors.


Latest articles:  (any category)

A 2020 Radiology Coding Change You Need To Know
February 10th, 2020 - Aimee Wilcox, CPMA, CCS-P, CST, MA, MT, Director of Content
The radiology section of the 2020 CPT© has 1 new, 18 revised, and 14 deleted codes. Interestingly, six of the 14 deleted codes were specific to reporting single-photon computerized tomographic (SPECT) imaging services of the brain, heart, liver, bladder, and others. If your organization reports radiology services, it is...
Documenting telephone calls at your dental practice is just as important as documenting patient visits.
February 4th, 2020 - Christine Taxin
Documenting telephone calls at your dental practice is just as important as documenting patient visits. Similar to other documentation, the common rule when it comes to call documentation is that if it is not documented, it did not happen. Therefore, every clinically relevant telephone call should be documented. Clinically relevant calls ...
CPT 10-Year Historical Content - Now Available!
January 22nd, 2020 - Find-A-Code
Did You Know? We now offer Historical CPT Content in 2-year, 5-year, or 10-year options! Utilize access to specific CPT historical data for previous years using rules effective at that specific time. If you’ve added UCR fees to your account, you can use Historical CPT Content to view UCR fees from ...
Inadequate Exclusion Screenings Could Put Your Practice at Risk
January 21st, 2020 - Wyn Staheli, Director of Research
Exclusion screenings require far more than just checking a name on a federal database at the time you are hiring someone. Far too many providers don’t realize that in order to meet compliance requirements, there is MUCH more involved. There are actually over 40 exclusion screening databases/lists that need to be checked.
Q/A: How do we Bill Massage Services?
January 21st, 2020 - Wyn Staheli, Director of Research
Question: We are adding a massage therapist soon and have some questions about billing their services.
Billing for Telemedicine in Chiropractic
January 14th, 2020 - Evan M. Gwilliam DC MBA BS CPC CCPC QCC CPC-I MCS-P CPMA CMHP
Many large private payers recognize the potential cost savings and improved health outcomes that telemedicine can help achieve, therefore they are often willing to cover it. While there are several considerations, there could be certain circumstances where telemedicine might apply to chiropractic care.
Non-Surgical Periodontal Treatment
January 14th, 2020 - Christine Taxin
AAP treatment guidelines stress that periodontal health should be achieved in the least invasive and most cost-effective manner. This is often accomplished through non-surgical periodontal treatment.Non-surgical periodontal treatment does have its limitations. When it does not achieve periodontal health, surgery may be indicated to restore periodontal health.SCALING AND ROOT PLANINGScaling ...



About Codapedia by innoviHealth® Contact Us Terms of Use Privacy Policy Advertise with Us

innoviHealth® - 62 E 300 North, Spanish Fork, UT 84660 - Phone 801-770-4203 (9-5 Mountain)

Copyright © 2000-2020 innoviHealth Systems®, Inc. - CPT® copyright American Medical Association