A physician group wants to bill Medicare incident-to for services f…

Question

A physician group wants to bill Medicare incident-to for services furnished by an APP who works purely as an independent contractor with no W-2 or leased-employee arrangement. What is the compliance concern?

Accepted Answer

Incident-to generally requires a W-2 employee or qualifying leased-employee relationship; a typical independent contractor APP does not meet that element. — Incident-to isn’t a handshake deal with a 1099 APP. Medicare looks for a real employee or leased-employee hookup. Sharing an EHR login doesn’t turn a contractor into incident-to staff.

Answer

Independent contractors automatically qualify for incident-to if they use the group’s EHR.

Answer

Employment status is irrelevant as long as the APP shares the same taxonomy code.

Answer

Incident-to is allowed for contractors only when the patient self-pays.

A physician group wants to bill Medicare incident-to for services furnished by an APP who works purely as an independent contractor with no W-2 or leased-employee arrangement. What is the compliance concern?

Short Explanation

Full Explanation