![]() ![]() The physician is then allowed to bill for the service at 100 percent of the MPFS rate as if he or she personally performed the entire visit. Medicare also permits physicians who provide evaluation and management (E/M) services to hospital inpatients, to hospital outpatients, or in the emergency department to bill for “shared visits.” In a shared visit, the physician performs an E/M service, including face-to-face time with the patient, but “shares” the visit with an NPP who also works in the physician's group. In a clinic setting, Medicare does not require that the physician who ordered the services be the one who supervises, as long as the other incident-to rules are met. Buildings separated by a walkway, for example, would not qualify as an office suite. The physician need not be in the room with the supervised practitioner an “office suite” generally is considered to include offices within one building, under a single lease. These services must be performed under direct supervision, meaning that the physician is physically present in the office suite and immediately available to provide assistance and direction when the service is performed. For the services to be “integral,” the physician must provide the initial service while the NPP or other personnel provide subsequent services during a course of treatment. The services must be of the type commonly furnished in a physician's office or clinic (as opposed to physicians working in a hospital setting). Incident-to services must be an integral – although incidental – part of the physician's personal professional services and be part of the patient's normal course of treatment. ![]() These specific requirements only apply to Medicare, but some private insurance plans allow incident-to billing using similar rules. ![]() But to qualify for incident-to designation, the services must meet certain requirements. Effectively using incident-to rules can allow a practice to enhance revenues by ensuring that much of the NPP's time rendering services is billed at a higher rate and is increasing the range of services the practice offers. That permits the practice to bill for services provided by an NPP and supervised by a physician at the full MPFS rate, as if the physician personally performed the service. Physicians often work with NPPs on an incident-to basis. PAs and NPs can bill under their own names and receive 85 percent of the Medicare physician fee schedule (MPFS) rate. Medicare recognizes PAs, NPs, and CNSs as equivalent to physicians for coverage purposes but only if their state licensure laws permit them to perform the service in question. That said, Medicare defines “physician services” for some payment purposes as services performed not only by MDs and DOs but also by PAs, NPs, clinical nurse specialists (CNSs), physical therapists, occupational therapists, speech language pathologists, audiologists, certified registered nurse anesthetists, and others. ![]()
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