Incident-To Billing for Medicare

Question:

I was told for our Medicare patients in order for my PA to report incident-to the physician, that the supervising physician must be in the office.  Is that correct?  We are billing new and established patients under a physician’s NPI number even if there is no physician in the office.

Answer:

To bill Incident-to services a physician must be in the office suite, but it does not need to be the Advanced Practice Provider’s (APPs) supervisor. In addition, you cannot bill incident-to for a new patient when the APP sees them. “Incident To” can only occur for an established patient with an established plan of care originally developed by a physician. If the plan of care changes or the patient has a new or worsening problem, it must be billed under the APP's NPI number. For Medicare, when billing under the APPs NPI number 85% is paid under the Medicare Physician Fee Schedule.

*This response is based on the best information available as of 6/05/25.