In its June 2019 report on Medicare payment policy to Congress, the Medicare Payment Advisory Commission recommended ending "incident to" billing for advanced practice registered nurses and physician assistants.
Seven things to know:
1. "Incident to" billing permits nonphysician practitioners to bill certain services using the physician's CMS-issued unique 10-digit identification number, known as a national provider identifier.
2. Billing "incident to" services is beneficial for nonphysician practitioners because reimbursement for "incident to" billing is 100 percent of the Medicare fee schedule rather than the typical 85 percent, according to AAPC, a medical coding training and certification association.
3. CMS allows "incident to" billing for services that take place in settings "other than a hospital or skilled nursing facility."
4. Nonphysician practitioners cannot use "incident to" billing for new patients or for a new issue for an established patient.
5. The patient's care must begin with a Medicare-credentialed physician, but a nonphysician practitioner may provide follow-up care if supervised by a qualified provider, according to AAPC, which cites federal guidelines.
6. The association also said "incident to" billing applies to services typically performed in the office setting and must be part of the normal care of a diagnosis or illness.
7. During a presentation in December, MedPAC staff told commission members MedPAC analyses suggest "a substantial share of services" that nonphysician practitioners perform are billed "incident to."
Read more about "incident to" billing requirements here.
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