Figure out what incident-to requirements you have to meet
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Question: Is there any situation in which a group can bill all services and all providers (including other physicians) under just the head doctor? I know we can go and bill NPP services incident-to another physician, but what about other physicians?
Answer: No, you cant bill services for all providers under one of the groups medical doctors. One reason could be because you may not bill one doctor incident-to another doctor. Incident-to rules do not apply here as they pertain to the relationship between a physician and a non-physician practitioner (NPP).
Bottom line: Its never acceptable to bill services provided by one physician under another physicians name or national provider identifier (NPI). Billing under the name of a physician who did not perform the service can lead to troubles including false claims submission allegations.
However, you can report NPP services incident-to the medical director if the visits meet all the criteria of incident-to services. The NPP could be a physician assistant (PA), nurse practitioner (NP) or clinical nurse specialist as long as the NPP meets state and federal guidelines to provide the service. The NPP must be "licensed by the state under various programs to aid or act in the place of the physician," The Medicare Benefit Policy Manual, Chapter 15 reads.
Good bet: For NPP qualifications check your state and local Medicare Audit Contractors (MAC) or Medicare carriers regulations. If the NPP doesnt meet one or both sets of guidelines, do not bill incident-to for physician level services (like 99212-99215, office or outpatient visit)