The $118,000 incident-to incident

A practice that follows the rules for incident-to billing can expect 100% of reimbursement for a non-physician practitioner’s (NPP) services reported under a physician’s provider number, rather than 85% billed under the NPP’s ID. A practice that breaks the rules for incident-to billing can expect trouble. And even the appearance of improper incident-to billing can have bank balance-busting repercussions, as a physician in Texarkana, Texas recently learned.

 

Donald Douglas, M.D. will pay $118,000 to resolve allegations that he billed for services performed by advance practice nurses (APNs) who worked for his practice incident-to “even when a physician was not available to supervise the APNs’ services,” the Department of Justice (DOJ) announced in a May 17 press release.

 

The press release doesn’t provide details about why the DOJ believed the APNs’ services were not provided under the direct supervision of a physician. That is, a physician was in the office suite and immediately available to assist the NPPs if necessary. The DOJ made it clear that the doctor did not admit wrongdoing and that he cooperated with the investigation. In addition, “the United States does not allege the services were not provided or that Dr. Douglas’ APNs provided inferior care.”

 

That should be a comfort to everyone in the practice, but it should also drive home the lesson that practices must follow and be able to prove that they followed the rules for incident-to billing to stay out of trouble.