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Ask-A-Consultant: Incident-to Billing for NPP services


What are the requirements for incident-to billing for NPP services for prenatal care in the office? What are the physician's obligations in this situation?
Washington, DC


For Medicare purposes, the incident-to billing guidelines are the same for all providers regardless of specialty and are as follows:
However, patients receiving prenatal care are more likely to be insured by private payors, which may or may not follow Medicare's incident-to guidelines. State laws may also have more stringent requirements for supervision and signatures. Therefore, it is important to obtain policies from your top payors and to review your state's laws with regard to the medical profession.

Bottom line, it is the physician's responsibility to provide personal services in the event there are any complications during the pre-natal period and to ensure the NPP is qualified to provide pre-natal care. Above all, remember that the physician is ultimately responsible for all incident-to services provided, so, for risk management and quality of care purposes, it is in his/her best interest to appropriately supervise all NPP providers.


Mary Beth Black, CPC
Senior Associate

MMA does not provide legal, accounting, or tax advice.  If you need assistance in these areas, we recommend that you consult a qualified professional.  In addition, please note that a client relationship with MMA is not established by the submission of a question to this forum or by the publishing of MMA's response.

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Medical Management Associates, Inc.
3330 Cumberland Boulevard Suite 200 Atlanta, GA 30339
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