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March 27, 2018

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Medical Coding News Archives

Incident-to Policy Is Beefed Up

May 13, 2008:
New guidelines released by the Centers for Medicare and Medicaid Services (CMS) address the increase in the number of services reported as “incident to.”

The new guidelines specifically address such areas as:
  • Incident-to requirements for coverage of drugs and biologicals that are not usually self-administered
  • Services and supplies furnished incident to a physician’s/nonphysician practitioner’s (NPP’s) professional service
  • Incident-to physician’s/NPP’s professional services in office- or physician-/NPP-owned and operated clinics
  • Services of nonphysician personnel furnished incident to a physician’s services
  • Incident-to physician’s/NPP’s services in physician/NPP owned and operated clinics
The new guidelines more clearly define direct supervision as a necessary component of incident-to billing. The new guidelines state that “direct supervision in the office or physician/NPP owned and operated clinic setting has the same meaning as it does for diagnostic tests (see 42 CFR 410.32(3)” and goes on to say that “direct supervision means the physician/NPP must be present in the office suite and immediately available and able to provide assistance and direction throughout the time the service is performed. Direct supervision does not mean that the physician/NPP must be present in the same room with the employee providing the service, if the supervisor is in the office suite. In cases where the definition of ‘office suite’ is questionable, contact the Medicare contractor concerning acceptable locations for the supervisor.”

Deborah C. Hall
Clinical/Technical Editor


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