decisionhealth Newsletters, Part B News - 2019 Issue 6 (June)
Avoid a costly incident: 4 tips to thwart incident-to billing mistakes
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Article Overview
This article examines Medicare incident-to billing compliance for physician practices, using an OIG-related settlement as context. It focuses on why supervision and documentation requirements matter, how practices can evaluate whether incident-to billing is appropriate, and what general compliance issues administrators and coders should watch for. The discussion is aimed at practice managers, coders, compliance staff, and clinicians working with nonphysician practitioners under Medicare rules.
Why This Topic Matters
Incident-to billing can affect Medicare reimbursement and compliance risk, so misunderstanding the rules may lead to payment problems or audit exposure. The article helps readers recognize the operational and documentation areas that commonly trigger concern.
Article Sections
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Incident-to billing and the OIG case context
Introduces the compliance issue and places it in the context of a recent federal investigation and settlement involving Medicare claims.
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Supervision and compliance concerns
Explains the importance of physician supervision and why the topic draws attention from government payers and investigators.
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Paying ‘doctor dollars’
Discusses the reimbursement difference between billing under a physician versus a nonphysician practitioner and why practices monitor this area closely.
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Follow the golden rule
Covers the first compliance theme presented in the article, centered on maintaining a consistent plan of care and proper physician involvement.
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Watch your documentation, including signatures
Addresses recordkeeping expectations and why signatures and supporting documentation can raise questions during review.
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Pay attention to your physical presence
Focuses on the practical issue of where the supervising physician must be during the reported service and the compliance implications of separation.
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Make a business decision
Summarizes the operational choice practices face when deciding whether to use incident-to billing or have services billed separately.
What You Will Learn
- The general compliance concerns surrounding Medicare incident-to billing
- How physician supervision affects billing under a practice model using nonphysician practitioners
- Why documentation and record review matter in incident-to compliance
- How practices may evaluate operational tradeoffs when deciding whether to bill incident-to
Who Should Read This
- Physician practices
- Medical coders
- Compliance staff
- Practice managers
- Clinicians working with nonphysician practitioners
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