What Is Incident-To-Billing? A Brief Guide
Incident to billing is a term used in the healthcare industry to describe a billing arrangement in which a physician or other medical professional bills Medicare for certain medical services that are performed by a non-physician professional, such as a physician’s assistant or nurse, “incident to” the physician’s services. In other words, incident-to-billing refers to services that are provided as an extension of a physician’s professional services and are performed under the direct supervision of the physician. The services must meet certain requirements set by the Centers for Medicare and Medicaid Services (CMS) to be eligible for incident-to billing.
Incident-to-Billing Examples​
Here are some examples of services that can be billed as incident-to:
- Administering injections
- Drawing blood
- Performing wound care
- Administering oxygen
- Assisting with a diagnostic test
The Incident-to-Billing Process​
The following is a detailed explanation of the incident-to-billing process:
Identify The Services That Can Be Billed As Incident-To:
It is important to determine which services can be billed as incident-to based on the guidelines set by the Centers for Medicare and Medicaid Services (CMS). Examples of services that can be billed as incident-to include administering injections, drawing blood, performing wound care, administering oxygen, and assisting with a diagnostic test.
Verify The Physician's Presence:
To be eligible for incident-to billing, the physician must be physically present in the office suite while the services are being performed, although they do not need to be in the room.
Bill The Professional Component:
The physician must bill for the professional component of the services. This includes the medical decision-making and interpretation of the results of the services performed.
Bill The Technical Component:
The non-physician professional must bill for the technical component of the services. This includes the actual performance of the services.
Use The Correct Billing Codes:
When billing for incident-to-services, it is important to use the correct Current Procedural Terminology (CPT) codes. The CPT codes are used to describe the medical services performed.
Provide Appropriate Documentation:
To support the incident-to-billing, it is important to provide appropriate documentation of the services performed, including the physician’s presence and direct supervision of the non-physician professional.
Submit The Claims:
Once the appropriate documentation is in place, the claims for the incident-to services can be submitted to Medicare for reimbursement.
The incident-to-billing process involves identifying the services that can be billed as incident-to, verifying the physician’s presence, billing the professional and technical components, using the correct billing codes, providing appropriate documentation, and submitting the claims to Medicare for reimbursement. It is important to follow the guidelines set by CMS to ensure the incident-to-billing is done correctly.
Incident-to-Billing Guidelines​
To be eligible for incident-to-billing, the services must meet certain requirements set by the Centers for Medicare and Medicaid Services (CMS). The following are the guidelines for incident-to billing:
- The services must be performed under the direct supervision of the physician.
- The services must be an integral, although incidental, part of the physician’s professional services.
- The services must be performed in the physician’s office or in a place of service that is considered part of the physician’s office.
- The physician must be physically present in the office suite while the services are being performed, although they do not need to be in the room.
- The physician must bill for the professional component of the services, and the non physician professional must bill for the technical component of the services.
Incident-to-Billing Guidelines 2021​
Incident-to-billing guidelines are established by the Centers for Medicare and Medicaid Services (CMS) to regulate how incident-to services are billed and reimbursed by Medicare. These guidelines are updated regularly and it is important for healthcare providers to stay current with the latest changes. The following are the key guidelines for incident-to billing in 2021:
Direct Supervision:
To be eligible for incident-to billing, the services must be performed under the direct supervision of a physician. This means the physician must be physically present in the office suite while the services are being performed, although they do not need to be in the room.
Eligible Services:
Only certain services are eligible for incident-to billing. Examples of services that can be billed as incident-to include administering injections, drawing blood, performing wound care, administering oxygen, and assisting with a diagnostic test.
Professional & Technical Components
Incident-to-billing involves billing for both the professional and technical components of the services. The physician must bill for the professional component, which includes the medical decision-making and interpretation of the results of the services performed. The non-physician professional must bill for the technical component, which includes the actual performance of the services.
Billing Codes:
When billing for incident-to-services, it is important to use the correct Current Procedural Terminology (CPT) codes. The CPT codes are used to describe the medical services performed.
Documentation:
To support the incident-to-billing, it is important to provide appropriate documentation of the services performed, including the physician’s presence and direct supervision of the non-physician professional.
Reimbursement:
Once the appropriate documentation is in place, the claims for the incident-to services can be submitted to Medicare for reimbursement.
Medicare Incident-to-Billing Rules for 2022​
CMS periodically updates its incident-to-billing guidelines, and the latest set of rules was released in 2022. The key changes in the 2022 rules include:
- The physician must be present in the office suite, but they do not need to be in the room where the services are being performed.
- The services must be an integral, although incidental, part of the physician’s professional services and must be performed under the physician’s direct supervision.
- The physician must bill for the professional component of the services, and the non-physician professional must bill for the technical component of the services.
It is important to note that incident-to-billing guidelines are subject to change and healthcare providers must stay informed of the latest changes to ensure they are in compliance. Incorrect incident-to-billing can result in denied claims, reimbursement reductions, and potential legal consequences. By following the incident-to-billing guidelines, healthcare providers can ensure they are providing high-quality care to their patients and are reimbursed fairly for their services.
Wrap Up!​
Incident-to-billing is a billing arrangement in which a physician bills Medicare for certain medical services that are performed by a non-physician professional under the physician’s direct supervision. The guidelines for incident-to billing are set by CMS, and the rules were updated in 2022. Some examples of services that can be billed as incident-to include administering injections, drawing blood, performing wound care, administering oxygen, and assisting with a diagnostic test.
