CREDENTIALING
By Machelle Giordon, Credentialing Specialist
QUALIFICATIONS FOR INCIDENT TO "RULE"
If you are considering to bill “incident to” the physician when a qualified non-physician practitioner (NPP) performs the services for Medicare patients. Please consider the following criteria before billing your claims…….
Did the primary care physician establish a plan of care?
To qualify for incident-to billing, the physician must see Medicare patients during the initial visit and establish plan of care. Only than can the non-physician continue the treatment plan by the physician. However, if the non-physician during treatment found a new problem that was not detected by the physician, this finding cannot be reported as incident-to.
Is the Non-Physician Licensed?
Any Physician hiring an NPP must be absolutely sure they have proper credentials to perform the service. The NPP could be a nurse practitioner or physician assistant, as long as they meet state regulations and all federal requirements.
Did the visit meet all supervision requirements?
Medicare requires that physicians provide direct supervision in order to bill incident-to. The physician doesn’t have to be present in the same room as the NPP, but they must be available for immediate assistance.
Is the patient’s medical record keeping in order?
Experts recommend physicians to include in the plan of care, that NPP is approved in involvement of this patient treatment. It seems important to show the link between the NPP and the patient. At least if a random audit will show up, the patient s chart will reflect the physician’s decision to allocate continuation of care of the NPP.
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