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Can a Psychiatric Nurse Practitioner Bill "Incident To" for Other Providers? Well....maybe?

This question comes up frequently, most often surrounded by credentialing issues. "Well, while I am waiting for my therapist (or new NP) to be credentialed, I can just bill incident to and get paid"... not so fast! There are specific requirements that have to be met in order to bill an "incident to", if you do not follow the guidelines you could end up being charged with Medicare and/or insurance fraud.

I don't know about you, but I don't want to end up wearing an orange jumpsuit because I was trying to get paid.


If you have had any conversations with insurances, you know that you can call three times, speak to three different people, and get three different answers. I do recommend that you contact them and inquire, but whatever answer you get from them, get it in writing. That way if you are ever audited, and someone else tells you that you are billing incorrectly, you have something to cover yourself. Keep it in a nice "cover your rear-end" file to pull out if needed. Medicare and commercial insurance plans don't always follow the same rules. Insurance companies vary from payor to payor. Just be careful and get it in writing! I have included Medicare guidelines to "incident to" billing below.

Make sure you are specific, when you are talking to the insurance company. "I am a credentialed Psychiatric Nurse Practitioner with your company, and I want to bill incident to for my therapist who is not credentialed (or is getting credentialed) with your company (or a new grad who is under supervision). Believe it to not, there are insurance companies out there that will not allow you to bill "incident to" for a new grad, and some won't even cover payment for nurse practitioners that are still under supervision.

To make it even more complicated, not only can it vary insurance payor to insurance payor, it can vary state to state. So if you are thinking about seeing patients in several states, make sure you are informed, documenting, and billing legally.

Telehealth can throw a whole other problem in the mix. How are you following the "supervising" requirement via telehealth?

I am not a lawyer, but I suggest you cover yourself if you are contemplating the use of "incident to" billing. Laws change, so keep yourself up to date on any changes.

These links offer great explanations and some clarification:

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