“Incident-to” vs “Direct” Billing

Question:

Our nurse practitioner saw a new patient (Medicare) in the office to evaluate sinus complaints. The nurse practitioner developed the plan of care. The patient was scheduled to follow up with the Nurse Practitioner. The patient returned to the nurse practitioner for a return visit with the same problem, and there were no changes in the plan of care. Can the NP bill this “Incident to” the physician since it is an established patient with an established plan of care and the physician was in the office?

Answer:

This is a great question. While the second visit is for an established patient with no change in the care plan, the nurse practitioner must still bill it as “direct.” To move this to an “Incident-to” encounter, there must be an independent encounter with the physician develops the plan of care.

*This response is based on the best information available as of 12/5/24.