Incident-to
Incident-to billing lets a non-physician practitioner's service be billed under a supervising physician's NPI when strict requirements are met, paying at the physician rate.
Updated
Incident-to is a Medicare billing concept that allows a service furnished by a non-physician practitioner (such as a nurse practitioner, physician assistant, or clinical nurse specialist) to be billed under the supervising physician's National Provider Identifier (NPI) when specific requirements are met — including that the physician established the plan of care, the service is part of that plan, and the physician provides direct supervision as required.
When the incident-to requirements are satisfied, the service is paid at 100% of the physician fee schedule rate under the physician's NPI. When they are not — for example, when the supervision or plan-of-care conditions are not met — the service is typically billed under the practitioner's own NPI at a reduced rate (commonly 85% for Medicare).
In practice
Because incident-to payment is conditional on supervisory and plan-of-care rules that can change by setting and by date, a service billed incident-to that does not meet the requirements is an overpayment risk and a common audit finding. Verifying the supervision arrangement and that the physician originated the plan of care is part of billing incident-to, not an optional check.
Commonly confused with
- Split/shared visit: A split/shared visit is jointly furnished by a physician and a non-physician practitioner in a facility setting and split between them; incident-to is a service furnished by the practitioner alone under the physician's supervision in a non-facility setting.
- NPI: Incident-to bills under the supervising physician's NPI; the practitioner's own NPI is used when incident-to requirements are not met.