Incident to is defined by the Centers for Medicare & Medicaid Services (CMS) as “an integral, although incidental, part of the physician’s personal professional services to the patient.” Incident-to services include those usually performed by clinical office staff (eg, vital signs, injections) or those performed personally by the physician (eg, minor surgery, fracture care, evaluation and management [E/M] of a patient).

Services performed by nonphysician providers (NPPs) (eg, nurse practitioners, physician assistants [PAs], therapists, nurses, medical assistants, technicians) that do not have their own provider number are reported as incident to under the physician’s provider identification number (PIN) and are paid according to the physician fee schedule. In other words, they are reported as if they were performed by the physician.

Licensed NPPs (eg, clinical nurse specialists, clinical nurse practitioners) may provide medically necessary services within their state’s scope of practice without direct physician supervision and may report their services...

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