I recently received the following question about incident-to billing:
My compliance officer asked me to reach out to … seek direction on where we could find current information about [whether] it is permitted to bill incident to when a medical assistant is supervised and billed under a PA [physician assistant] as the supervising physician.
We read your 2016 article … about [Medicare’s Chronic Care Management] and [Transitional Care Management] billing. Oregon recently passed laws where PAs enter into a collaborative agreement with providers. [Does this change whether the Centers for Medicare & Medicaid Services] will now allow incident-to billing with PAs supervising [medical assistants]?
In the Medicare Benefit Policy Manual, the definition of physician includes physician assistants and nurse practitioners. As demonstrated in the 2016 Public Affairs article, medical assistants are classified as auxiliary personnel and clinical staff under Medicare law.
Therefore, medical assistants’ services performed incident to those of a PA may be billed incident to the services of the PA in the same way that they may be billed incident to the services of an MD or DO.