Caution in Billing Incident-To
November 3, 2020
by Sean Weiss, Partner & VP of Compliance
Medicare will pay the higher physician rate for services rendered by non-physician providers (NPP) if the services are “incident to” the services of a physician. Services must be provided under the direct supervision of a physician. However, for years now, I have cautioned providers about billing “Incident-To” given the level of complexity. In 2017, I assisted OIG with a study tied to Incident-To Services. As I participated in discussions with auditors, investigators, and special counsel, it was clear that NPPs needed to be credentialed and bill under their own number. The minimal financial difference is not worth the risk as detailed in a settlement just released Friday, October 30,2020 by the DoJ (Memphis Physicians Agree to Pay More than $340,000 for Alleged Overbillling). This settlement was the result of a qui tam that alleged the physicians violated the False Claims Act.
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