“Incident to” is a topic that has been covered for years at various association meetings and articles, yet the subject is continually misunderstood.  I would like to review the finer points as a refresher as I continue to hear the same questions.  There may be more details in the reimbursement policy or the Medicaid Billing Manuals; however, the questions I receive are applicable to these 3 items.  If you haven’t met 1 and 2, there is no need to continuing past “Go” or Collecting $200 to read the policy finer points.

Incident to is meant to be billed under the physician IF (in summary):

  1. The physician saw the patient for the initial problem & develops the plan of care and the midlevel provider (MLP) is seeing the patient as a follow-up to that plan of care, and
  2. The physician is in the suite, except with Texas Medicaid and maybe other programs that require physician interaction on every visit to be billed under the physician, and NOT,
  3. New patient visits by a MLP CANNOT be billed under the physician at any time, even if the physician is in the suite. See item 1.

If you are a multispecialty clinic or a family med/internal med/Primary Care, the physician may see the patient for diabetes and develop a plan of care, the MLP would have to see the patient for diabetes for that to be considered incident to.  If the MLP sees the patient for the flu, cold, allergies, rash, those would be billed under the MLP not the physician.  Also, if the MLP does see the patient for diabetes as a new problem, again incident to does not apply.


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Prepared by: Angela Miller, CMC, CHC with Medical Auditing Solutions, LLC