Incident-to Billing for Medicare

Question:

We bill incident-to for Medicare patients in our office for our physician assistants. We don’t have a Otolaryngologist in the office on Friday afternoons but our 5 PAs are in seeing patients. Can we bill their services “incident to” the physician they work for?

Answer:

You are not able to bill the service Incident-to when a physician is not in the office suite. A supervising physician must be on-site providing supervision in order to bill “incident to.” In your case, you will bill direct using the PA’s name and NPI (national provider identification) number.

*This response is based on the best information available as of 7/31/25.

 
 
 
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