Are incident to services worth the risk

August 13th, 2018

Incident-to services allow non-physician practitioners (NPPs) such as nurse practitioners and physician assistants to bill under a supervising physician if they perform services that are incidental to a physician-created plan of care.

Incident-to billing offers two key benefits: First, the physician is reimbursed at 100% of the contracted rate with the payer, while NPPs typically are reimbursed at 80% or 85% of the contracted rate, so if an NPP can bill under the physician, the reimbursement is higher. Second, billing under the physician allows a non-credentialed NPP to see patients, barring any payer-specific rules that may require the NPP to be credentialed.

However, there are also two significant disadvantages to incident-to billing. First and foremost, the rules are difficult to follow and potentially disruptive to clinical workflow, as we will explore later in this tip; if the rules are not followed carefully, incident-to can be a major compliance risk. Second, the various commercial payers have different rules on incident-to services, and these may not be easily available for review.

Incident-to requirements

Let’s start by going over the incident-to rules below.

Top incident-to questions

Now that we have reviewed the requirements for incident-to services, let’s look at some of the most common questions that arise when dealing with incident-to.

Conclusion: Is incident-to worth the compliance risk?

There’s no question that incident-to services can offer flexibility and increased reimbursement when using NPPs in the outpatient setting. However, if you decide to bill under incident-to guidelines, you are electing to comply with a complex set of rules that vary by payer, and you must assume full responsibility for learning and following each payer’s rules.


Are incident to services worth the risk. (2018, August 13). Find-A-Code Articles. Retrieved from

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