“Incident-to” is a Medicare billing policy that allows physician assistants to bill Medicare with the physician’s National Provider Identifier (NPI). They can bill at 100 percent reimbursement if Medicare’s strict “incident-to” guidelines are met.
Those guidelines are:
- Services are provided in a physician’s office or physician’s clinic.
- The physician sees the Medicare patient on the initial visit and establishes a diagnosis and treatment plan. The PA sees the patient on the follow-up visit.
- For established Medicare patients with a new problem, the physician sees the Medicare patient first for the new problem and establishes a diagnosis and treatment plan. The PA sees the patient on the follow-up visit.
- The physician is on site, within the suite of offices.
- The physician continues to see the patient at a frequency that reflects ongoing management of the patient’s care.
- Services are within the PA’s state law scope of practice.
If any of the first five bulleted items are not met, PAs should bill Medicare with the PA’s NPI, as rendering provider, with reimbursement at 85 percent.
Remember, PAs may see new Medicare patients and established Medicare patients with new problems with their state-law level of supervision. But they must bill Medicare with their own NPI with reimbursement at 85 percent.
Please refer to Medicare’s transmittal number 1764 for more information on “incident-to” billing. See especially section 2050.2.
Andrew Iwanik is AAPA senior manager for reimbursement advocacy.