Incident to Quick Reference Chart

Location	PT Status	Scenario	Who Bills	Comments
Office	New patient	NPP sees patient - MD not present in office suite	NPP bills for the service under the NPP NPI	NPP documents full office visit
Office	New patient	MD sees patient, with some participation by NPP or clinical staff	MD bills for the service under the MD NPI	NPP can document ROS, PFSH, vitals. Incident to concept does not apply for initial office visits.
Office	Established patient	NPP sees patient - MD not present in office suite	NPP bills for the service under the NPP NPI	Incident to requirement not met if MD not immediately available to NPP
Office	Established patient	NPP sees patient (no new problems); MD immediately available in office suite for supervision if needed	Service may be billed under MD's NPI. MD must see the patient periodically and document MD involvement and oversight of care	Incident to rules apply in this scenario
Office	Established patient	NPP sees patient; no change in Pt condition; MD documents their contribution to visit which must include F2F care	Service may be billed under the MD's NPI	NPP & MD document individual contribution(s) to care
Office	Established patient	NPP sees patient who presents with new or worsening problem	Service may be billed under MD's NPI, only if MD sees patient and documents participation; otherwise, service billed by NPP	NPP & MD document individual contribution(s) to care
Hospital (Inpatient Outpatient ER Observation)	Initial or subsequent care	NPP and MD "split/share" the visit and each performs a F2F component	MD must participate and perform and document at least one element of the E/M service, to bill under MD's NPI	Split/Shared rules apply in the hospital setting
Hospital (Inpatient Outpatient ER Observation)	Initial or subsequent care	MD Collaborates with NPP but MD does not have face to face with the patient.	NPP bills with NPP NPI	NPP & MD document contribution(s) F2F MD care required to bill with MD's NPI
Hospital (Inpatient Outpatient ER  Observation)	Initial or subsequent care	NPP sees patient without MD participation or collaboration	NPP bills with NPP NPI	NPP documents full service
Consultative Services: Split/Shared concept does not apply	N/A	N/A	N/A	Consultative services must be performed exclusively by the billing provider

 

Reviewed 10/10/2023