Do home care physicians bill “incident to” under the Medicare Policy Chapter 15, Section 60, Services and Supplies Furnished Incident to a Physicians/NPPs Professional Service?
No, valid housecall programs in the private sector should NOT bill “incident to,” although some attempt to do so. The reason they might attempt it is because “incident to” services are paid based upon 100% of the allowed physician fee schedule, whereas billing correctly under the NPP’s provider number pays at 85% of the allowed PFS amount. The reason no one logically can or should bill “incident to” is that there has always been a requirement for DIRECT supervision for “incident to” billing (physician/NPP in the building and immediately available at the time of provision of services). Why would one bill “incident to” when one payment will not cover the cost of both physician and NPP present during the housecall? Of course, a driver/employee, non-licensed staff accompanying the physician and taught to draw blood, do EKGs, etc. can be a valid reason to bill “incident to,” but the payment would not change, since the physician/NPP is already there billing the full amount. One EXCEPTION: Th
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