Coding for “Incident-to” Services
Services that physicians bill to Medicare but do not perform themselves are called “incident-to” services. These services usually are performed by nonphysician medical providers under close physician supervision. The authorization to bill for these incident-to services derives from the Social Security Act, which provides for Medicare coverage of services and supplies offered incident to the professional services of a physician. The underlying logic is that incident-to services are delivered as a necessary but incidental part of the physician’s professional services during diagnosis or treatment.
Practice Points
- Direct supervision of a nonphysician provider by a physician must be demonstrated for incident-to services. Not every type of visit is eligible for incident-to billing.
- Only management of established problems on established patients by nonphysician providers may qualify as incident-to services.
- Refer to state and payer regulations and rules for proper incident-to coding.
Final Thoughts
Attention to correct coding for incident-to services is particularly salient, as the Office of Inspector General (OIG) for the US Department of Health & Human Services has expressed concern that these services may be routinely coded incorrectly. Specifically, the OIG work plan for the 2013 fiscal year stated, “We will review physician billing for ‘incident-to’ services to determine whether payment for such services had a higher error rate than that for non–incident-to services.” The same report also cited a 2009 OIG review that found that “unqualified nonphysicians performed 21 percent of the services that physicians did not personally perform.”2 In short, coding for incident-to services is under scrutiny, and it may be useful for dermatologists to review their internal policies regarding incident-to services.
