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Reimbursement

Incident To Scenarios

What if you are seeing a Medicare patient for a follow up visit, where the physician had seen the patient on an initial visit and established a diagnosis and treatment plan – in the middle of the visit the patient complains of a minor new problem, like a cold?

May you complete the follow up visit and diagnosis and treat the cold and still bill the visit under the physician as an “incident to” visit?

The answer is maybe.

If you can diagnosis and treat the new problem, within the context of the original follow up visit, without increasing the complexity of the medical decision-making or providing a more detailed exam or expanding the history – then you can care for the new problem and bill the entire visit “incident to”



What if a PA sees a Medicare patient on the initial visit, a physician sees the Medicare patient on the 2nd visit and the PA again sees the patient on the 3rd visit.

May you bill the 3rd visit “incident to” the physician?

The answer is unclear.
  • If, on the second visit, the physician follows your diagnosis and treatment plan then on the 3rd visit you may not bill “incident to” the physician.
  • If, on the second visit, the physician documents verification of diagnosis and treatment plans, then you may be able to bill the 3rd visit “incident to”
  • If, on the second visit, the physician changes the plan of care you may be able to bill the 3rd visit “incident to”
  • If, on the second visit, the physician changes assessment from medical decision-making standpoint you may be able to bill “incident to”


What if you are working in a physician’s office that is connected to a hospital and you are seeing a Medicare patient for a follow up visit where a physician had provided the initial diagnosis and treatment plan, but the supervising physician during the follow up was in the connecting hospital.

Can you bill Medicare for the service “incident to?”

The answer is that you may NOT bill “incident to” in this scenario. The supervising physician must be onsite, within the suite of offices, and therefore may not be in the connecting hospital, down the hall or on a different floor in the building.

You may want to verify that your practice is a physician’s practice and not a hospital outpatient practice.


You are providing a follow up visit service but the physician who provided the initial visit service, diagnosed the patient and established the treatment plan is not on site. There is a physician on site, but she is not familiar with the case.

Can you bill Medicare “incident to?”

Yes, as long as the physician who is on site is in the same group and same specialty.

Bill Medicare with the NPI of the physician who is providing on site supervision.