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Incident-to services for Mental health

Duang Posted Mon 04th of March, 2019 22:57:47 PM
Does incident-to Medicare rule apply for commercial payers? Does the supervising provider have to be in the same building as the rendering/resident counselor for commercial payers??
SuperCoder Answered Tue 05th of March, 2019 03:16:09 AM


Thanks for your question.

Commercial payers may have different billing rules for incident-to guidelines and not all commercial payers follow incident-to guidelines, and some will not recognize certain NPPs.

The practice’s commercial contracts with whom you have contract with, should be clear as to whether services provided by employed non-physician practitioner can and should be billed under a supervising physician, and whether that payer follows incident-to guidelines.

As per the general rule, the supervising physician must be present in same office or suite and immediately available during the encounter to furnish assistance and direction when necessary.

Hope this helps.




Duang Posted Sun 19th of May, 2019 09:06:14 AM
Hi, I have a following questions re Mental health billing, and incident to service (aka supervisor claims). Can LPC supervise/oversee by another LPC? In another word, can LPC use the another LPC's NPI to submit the bill to the insurance carrier? If a non-license mental provider sees patient(s), can the non-license mental health provider (resident counselor) use LPC (supervisor)'s NPI to submit the bill? What does the definition of mental health supervisor? Thanks for your help in advance.
SuperCoder Answered Mon 20th of May, 2019 10:39:04 AM


Thanks for your query. Our team is working on the question and will reply soon.




Duang Posted Mon 20th of May, 2019 10:51:59 AM
Great. Thanks so much!!!
SuperCoder Answered Tue 21st of May, 2019 05:28:55 AM
Thanks for your patience.
According to Medicare, Physicians (medical doctors [MD] and doctors of osteopathy [DO]), particularly psychiatrists; Clinical psychologists (CP); Clinical social workers (CSW); Clinical nurse specialists (CNS); Nurse practitioners (NP); Physician assistants (PA); Certified nurse-midwives (CNM); and Independently Practicing Psychologists (IPP) are authorized by the act to receive payments for services incident to his or her own services. Incident to criteria must be met in all cases. Also, the supervising physician must be present in the same office suite and immediately available during the encounter to furnish assistance and direction when necessary.
Medicare does not recognize licensed professionals’ counselors (LPCs) as NPPs. However, their services may be billed as "incident to" a physician’s or clinical psychologist (CP) professional (having doctoral degree in psychology and licensed by the state) services if all of the "incident to" requirements are met.
Hope this information helps.
Duang Posted Tue 21st of May, 2019 07:06:06 AM
Very helpful. Thanks so much!
SuperCoder Answered Wed 22nd of May, 2019 01:35:22 AM

Thank you, happy to help.

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