Incident to is a concept that Medicare rules define for an incidental though integral service. This service is performed by auxiliary, clinical and ancillary staff. Definitions of each of these staff types change what types of services can be performed incident to. State licensing is also a part of what individuals are “allowed” to do under this concept that allows billing of the service to be done under the supervising provider. It gets confusing when you have incident to services performed by a Medical Assistant under supervision of a Nurse Practitioner or Physician’s Assistant and can also have services performed by the same Nurse Practitioner or Physician’s assistant under supervision of a physician.
Services as uncomplicated as an immunization can be billed incident to with ancillary staff performing the task. Other commonplace services in the office that are delegated to clinical staff can be things like most of an Annual Wellness visit or an ear irrigation. Even a low level Evaluation and Management (E&M) service such as a 99211 can be performed by the clinical staff under a plan of care determined by a billing provider if guidelines are met.
It is when those services become more complex like E&M services, above the level one, that things can get more confusing. Some may think it more complex, but the concept of an incidental though integral service still apply.
Coders, Billers, Office Managers, Office Administrators, Nurse Practitioners, Physician Assistants, Physicians