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

About the Presenter