Definition

 Those services or supplies furnished as an incidental part of the physician’s professional services in the course of diagnosing or treating an illness or injury. The auxiliary personnel are performing services as ordered by the physician. There must be a written plan documenting the services to be provided. The ordering provider may be a physician or an Advanced Practice Nurse or Physician Assistant so long as they are practicing within the State’s licensing guidelines. From hereafter this later group of professionals will be collectively and individually known as Non Physician Providers, NPP.
If the patient presents in clinic with a new problem or complaint the physician/NPP must first see the patient for this condition and establish a written order for the subsequent services. Incident-To services only apply when the patient has an established diagnostic and/or treatment plan written by the physician/NPP and the auxiliary personnel are following the written orders. Incident-To services are limited to SIU owned and/or leased outpatient clinic facilities.

Key Participants

Ordering Physician/NPP

• Physician/NPP who established the physician-patient relationship for the particular illness or injury
• Physician/NPP who established a written plan for subsequent care and treatment

Auxiliary Personnel

• Must be employed by the Ordering Physician/NPP (SIU and SIUP&S OK--No outside referrals accepted)
• Licensed or certified

Supervising Physician/NPP

• Physician/NPP in clinic (same linoleum) on the day the Incident-To services are provided and who is providing the “direct” supervision of the Auxiliary Personnel *
• The Ordering Physician/NPP and the Supervising Physician/NPP do not have to be the same provider.

* For Rural Health Clinics the Supervising Physician/NPP need only be accessible by phone and able to come to the clinic.

Medical Record Documentation Requirements

Ordering Physician/NPP

• Written orders for subsequent services

Auxiliary Personnel

• Details of services/supplies provided
• State specific Supervising Physician/NPP in clinic on the day services are provided
• Sign and date note

Supervising Physician/NPP

• No documentation required on the date the Incident To services are provided unless medical contact /interaction with patient

Services Typically Provided “Incident To” the Physician/NPP

• When the Auxiliary Personnel bill a 99211
• Coumadin Clinic
• Chemotherapy
• Injections/IV Infusions
• Allergy testing/shots

Medicare may have specific exclusions for what types of Auxiliary Personnel may provide Incident To services or exclusions of certain services that may not be billed as Incident To. Contact the SOM Office of Compliance or the SIU P&S Coding and Posting unit for additional details.

Scenario

Patient is seen by his primary care physician, Dr. Steward, who orders Coumadin monitoring in the Coumadin Clinic.  Patient comes to the Coumadin Clinic and the nurse documents the visit and the services rendered that day in the patient’s medical record.  Dr. Rosher is the nurse’s supervising physician in clinic at the time of the visit.  The nurse makes a written note to the medical record that Dr. Rosher was the supervising physician even though Dr Rosher was not the Ordering Physician/NPP. The nurse signs and dates the medical record entry. The charge for that day is billed in the name of Dr Rosher, the supervising physician. Dr Rosher is not required to make any entry in the medical record.