Billing for services that are performed as incident to the physician can be very confusing. To help clarify reporting, the Medicare incident-to guidelines are outlined herein with examples of how some procedures or services may be reported. Most Medicaid programs follow the Medicare incident-to requirements. Commercial payers may have their own requirements for reporting these services or they may also follow the Centers for Medicare & Medicaid Services (CMS) requirements.

The CMS defines incident to as “services incident to the service of a physician or other professional permitted by statute to bill for services incident to their services when those services meet all of the requirements applicable to the benefit.” In essence that means that in addition to a physician, licensed nonphysician practitioners (NPPs) may bill for their services when they provide medically necessary services within their state’s scope of practice without direct physician supervision and report their services separately...

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