decisionhealth Newsletters, Part B News - 2015 Issue 11 (November)
Supervising physician should bill incident-to services, CMS clarifies
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Article Overview
This article explains a CMS clarification in the final 2016 Medicare physician fee schedule affecting incident-to billing under Medicare. It covers who may bill, how supervision is distinguished from ordering or initiating care, the role of auxiliary personnel, and related policy updates discussed by CMS. The piece is useful for physicians, nonphysician practitioners, compliance staff, and billing teams who handle Medicare office-based services and want to understand the scope of the agency’s guidance.
Why This Topic Matters
The clarification affects claim submission responsibility and compliance for practices that use incident-to billing under Medicare. It is especially relevant for organizations managing supervision, documentation, and billing workflows for auxiliary personnel.
Article Sections
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Billing
Introduces the CMS clarification and frames the billing responsibility issue discussed in the article.
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Clarification removes gray area
Summarizes reactions from coding and compliance professionals and describes the broader billing context for incident-to services.
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Excluded NPPs can’t provide incident-to services
Covers CMS’s additional policy update regarding excluded or revoked personnel and notes discussion of future guidance development.
What You Will Learn
- How CMS addressed billing responsibility for incident-to services in the 2016 Medicare physician fee schedule
- What general supervision and billing concepts are being clarified for Medicare incident-to services
- Which types of personnel and compliance issues are discussed in connection with incident-to billing
- How CMS framed related policy changes affecting auxiliary personnel and future guidance
Who Should Read This
- Physicians
- Nonphysician practitioners
- Medical billers
- Coding professionals
- Compliance staff
- Practice administrators
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