RULE OF THUMB: To qualify as incident-to, Services must be part of the patient’s normal course of treatment, during which a physician personally performed an initial service and remains actively involved during treatment. The physician does not have to be physically present in the patient’s treatment room while the services are provided, but they must provide direct supervision; meaning they must be present in the office for assistance if necessary. A physician must perform subsequent services that reflect his/her continued active participation in and management of the patient’s care

When to bill under np:

• NP sees a patient for a new problem
• If an established patient brings up a new problem during NP visit

Common incident-To Services:

• Evaluation and management services (E/M)
• Chemotherapy administration
• Professional component of radiology services
• Minor surgery
• Office visits

services that do not apply:

• Any services that can be provided without a physician’s supervision cannot be billed as incident-to; laboratory services (except those such as coagulation monitoring which requires visits for medication management), flu shots, EKG, certain radiology services, etc.
• New patient office visits (CPT 99201-99205)
• Preventive examinations and yearly physical exams including Medicare IPPE, AWV, etc (CPT 99381-99387, 99391-99397)
• Any new problems encountered during the visit that are not addressed in the established plan of care. In this instance, the supervising physician needs to see the patient.
• No services can be billed incident-to when the supervising physician is not present in the office