2024 Medicare Rules Updates: Incident-To and Supervision Requirements

Event Materials (Key Required)

Medicare physician supervision rules and requirements are complex and confusing. You must master Medicare’s complex Incident-To supervision and billing rules to maximize your Physicians, NPPs & Mid-level provider’s reimbursement. This webinar will explore the fundamental elements of billing for services “Incident-To” a physician, Non-Physician Practitioners and Mid-Level Providers. The presentation will walk through the Medicare requirements for “Incident-To” billing. This webinar will also explore common examples to understand the intersection of “Incident-To” billing with state supervision requirements. Lastly, we will discuss recent enforcement actions to failing to compliantly bill services under the Medicare “Incident-To” rules.

Learning Objectives:

• Understand the Medicare incident-to billing rules for Physicians, NPPs and Mid-level Providers
• How state law may differ from Medicare and Commercial Payor requirements and how to balance it all
• How do the different types of supervision impact services like Incident-to and Split/Shared Services
• Review which services can be billed incident to a physician.
• Understand whose services can be billed incident to a physician.
• Understand proper documentation requirements
• Review the requisite supervision necessary for incident to billing
• Explore common examples faced in by providers
• Review recent enforcement actions
• Identify common best practices

Areas Covered in the Session:

• What is “Incident-To” Billing?
  • Applies Only to Medicare
  • Allows “physicians” to bill outpatient services provided by non-physician practitioners (“NPPs”)
• Physicians
• Non-Physician Practitioners (“NPPs”)
• Reimbursement for “Incident-To” Services
• Reimbursement Without “Incident-To” Billing
• All providers must be licensed and providing services within their scope of practice
• “Incident-To” Billing: The Law
• 42 C.F.R. § 410.26: Conditions for “Incident-To” Billing
• Non-Institutional Settings
• Common Issues
• Designated care management services under general supervision of the physician
  • G0502, G0503, G0504, G0507, CPT code 99487 and CPT code 99489
  • G0500: Behavioral Health Management services
  • CPT codes are for Complex Care Management
• Example: Ohio Supervision Requirements
• Example: Florida Supervision Requirements
• Supervision Example
• “Incident-To” Billing: Examples
• Physician Fee Schedule 2024 Updates – “Incident-To”
• Medicaid and “Incident-To”
• State Specific Laws
• More State Law Examples
• Benefits & Noncompliance
• Pros & Cons
• Noncompliance: OIG Concerns
• Noncompliance: False Claims Act
• Overpayments
• Best Practices and Resources

Suggested Attendees:

• Practice administrators, CEOs, COOs, CFOs
• Compliance Officers
• Healthcare CPAs
• Revenue Cycle managers
• Billers
• Licensed Providers
• Physicians and APPs
• Office Managers
• Billing Staff
• Medical Auditors
• Practice Managers
• Auditors
• Billing Companies
• Clinic Owners
• Chief Quality Officers
• Senior Internal Auditors
• Directors of Compliance
• Regulatory/ Risk Officers
• Government Employees
• General Counsel
• Compliance Attorneys

Presenter Biography:

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