Comply With Incident-To Billing

Conference Material (Password Required)

Incident-to billing is one of the most common mistakes a group practice can make. Physicians are able to bill certain services as “incident-to” the physician’s services, resulting in reimbursement at 100% of the Medicare physician fee schedule for nonphysician provider services. This presentation will go through the ins and outs of compliant, incident-to billing, and documentation requirements. This presentation will also review common misunderstandings and billing mistakes using real-world examples.

Learning Objectives:

• Gain knowledge of the incident-to billing rules
• Identify common mistakes and misinformation
• Explore strategies to mitigate non-compliance
• Learn about recent compliance enforcement
• To understand how incident-to is a compliance issue in multiple situations.
• To show how the incident-to concept applies to recently changed physician supervision requirements.
• To discuss incident-to-physician services in the provider-based clinic setting.
• To review how incident-to is involved in special situations such as the 3-Day Payment Window, RHCs and telemedicine.
• To appreciate how the rules for supervision have morphed over time.
• To understand the non-enforcement of the supervision rule for CAHs and small rural hospitals.
• To work through several case studies to illustrate the intricacies surrounding the incident-to concept.
• Identify common mistakes and misinformation
• Explore strategies to mitigate non-compliance

Areas Covered in the Session:

• What is Incident-to Billing?
• Physicians/ Incident-to Services
• Incident-To Rules for Non-Physician Practitioners (NPPs)
• Reimbursement for Incident-to Services
• Reimbursement without Incident to Billing
• Incident-to Billing: The Law 42 C.F.R. § 410.26: Conditions for Incident-to Billing
• Medicare Part B 9 Criteria for Payment
  • Services and supplies furnished in a non-institutional setting to a non-institutional patient
  • Integral services and supplies through incidental
  • Services and supplies furnished without charge or included in the bill of a physician
  • Services and supplies furnished in the office or clinic of a physician
  • Services and supplies under the direct supervision of the physician
  • Services and supplies furnished by the physician, practitioner with an incident to benefit, or auxiliary personnel
  • Services and supplies furnished in accordance with applicable State law
  • Physician/ NPP as an employee or an independent contractor
  • Drug incident to a physician’s service under section 1861(s)(2)(A)
• Non-institutional Setting
• Common Issues
• Ohio Supervision Requirements
• Florida Supervision Requirements
• Supervision Example
• Incident-to-Billing: Examples
• Physician Fee Schedule 2021 Updates – Incident-to
• Medicaid and Incident-to
• State Specific Laws
• State Law Examples
• Benefits & non-compliance
• Pros & Cons
• Noncompliance: OIG Concerns
• Noncompliance: False Claims Act
• Overpayments
• Best Practices and Resources
• Real-world examples
• Recent settlements
• Recent enforcements
• Hospital Payment For All Services Incident-To Physicians

Suggested Attendees:

• CEO
• CFO
• Licensed providers
• Physicians
• Office managers
• Billing staff
• Medical auditors
• Compliance officers
• Compliance director
• Privacy Officer
• Security Officer
• HIPAA Privacy Officers
• HIPAA Security Officers
• Information Security Officers
• Risk Managers
• Privacy Officers
• Health Information Managers
• Information Technology Managers
• Information Systems Managers
• Medical Office Managers
• Chief Financial Officers
• Systems Managers
• Chief Information Officer
• Healthcare Counsel/lawyer
• Operations Directors
• Insurers
• Hospitals
• Practice Groups
• Records Release Manager
• HR Director
• Electronic Healthcare Information Systems Staff

Presenter Biography:

Amanda Waesch has experience of 18 years and operates a national healthcare practice and is licensed in both Ohio and Florida. She primarily focuses her practice on healthcare, employment law, corporate law, and healthcare litigation and advises all types of employers, in particular healthcare providers, including, hospitals and physicians, on various matters.

She also chairs the firm’s litigation team that is primarily responsible for handling all reimbursement audits and appeals for her firm’s healthcare clients and heads up BMD’s Provider Relations, Audit, Appeals, and Negotiations Unit (PRAAN) which handles all-payer audits, appeals, overpayments and payment extrapolations.

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