Physician Assistant Billing for New and Established Patients

Question:

Our Physician Assistant saw a new Medicare Patient in the office for evaluation of left knee pain. She evaluated the patient and developed the plan of care. The patient was scheduled for a return visit with the Physician Assistant. During the return visit, the Physician Assistant evaluated the patient and made no changes to the plan of care—she continued the NSAIDs as the patient responded well.

Can she bill this  “Incident to” the physician who was in the office, as there was no change in the plan of care?

Answer:

Thanks for your inquiry. Although the second visit involves an established patient with no changes to the plan of care or new orders, the Physician Assistant must  submit the claim as the service provider. The 'Incident to' requirements have not been met.

To move this to an “Incident to” encounter, there must be an independent encounter with the physician who either agrees with or changes the plan of care. After the physician independently evaluates the patient and either agrees with or modifies the plan of care, subsequent encounters with the Physician Assistant may be reported as 'Incident to' if the requirements are met (e.g., implementation of the plan of care without new orders or changes to the plan of care).

*This response is based on the best information available as of 3/13/25.