The phrase incident-to is used in two very different ways in the Social Security Act (SSA). For physicians and practitioners, this phase is used for incident-to billing that relates to physician coding and billing for subordinate staff services. For hospitals, the phase is incident-to services that describe the major benefit category for hospitals under the Medicare program. Hospitals are paid for services that are incident-to services provided by physicians. Confusion is created through the very different ways in which incident-to must be interpreted.

Proper compliance with all the rules/regulations that relate to both incident-to billing and incident-to services is a major challenge. In this workshop, we compare and contrast the two different interpretations, how to remain compliant in both cases, and the interplay between these two concepts. Special situations such as for CAHs and RHCs will also be included. Also, the recent change by CMS to move from direct to general supervision for hospital outpatient services are discussed.

• Why does CMS frequently refer to incident-to services?
• What does incident-to really mean?
• How does incident-to relate to hospitals and physicians?
• Does incident-to have anything to do with physician supervision?
• Is incident-to a compliance issue?
• What are the rules and regulations surrounding incident-to services?
• Are there differences between physician clinics and hospitals relative to physician supervision?
• Why did CMS make the change from direct supervision to general supervision for hospital outpatient services?
• How do physician supervision and incident-to relate to the provider-based rule?
• How do physicians use the incident-to process for billing?
• How does the Social Security Act use the phrase incident-to?
• For physician supervision and incident-to, are there compliance implications?
• Is there anything special about CAHs and small rural hospitals?

Session Objectives:-

• To review and discuss the two different uses of the phrase, incident-to, as provided in the Social Security Act (SSA).
• To discuss the incident-to billing for physicians.
• To appreciate hospital payment relative to incident-to physician services.
• To understand physician supervision for both physicians and hospitals.
• To explore the change that CMS has made to move from direct supervision to general supervision for hospital outpatient services.
• To discuss hospital benefit categories under the SSA.
• To understand how incident-to is a compliance issue in multiple situations.
• To show how the incident-to concept applies to recently changed physician supervision requirements.
• To discuss incident-to physician services in the provider-based clinic setting.
• To review how incident-to is involved in special situations such as the 3-Day Payment Window, RHCs, and telemedicine.
• To appreciate how the rules for supervision have morphed over time.
• To understand the non-enforcement of the supervision rule for CAHs and small rural hospitals relative to the movement to general supervision.
• To work through several case studies to illustrate the intricacies surrounding the incident-to concept.

Agenda:-

• Introduction
  • Overview of the Incident-To Concept
  • Areas of Applicability of Incident-To Services
  • Compliance Concerns Surrounding the Incident-To Concept
  • Physician Supervision Requirements
• Incident-To and The Social Security Act
  • Physician Payment Through Incident-To Services
  • Hospital Payment Through Incident-To Services
  • Self-Administrable Drugs
  • Understanding the Two Different Uses of the Phrase Incident-To
  • Hospital Services Benefit Categories
• Incident-To Billing for Physicians
  • Physician Billing For Subordinate Staff Services
  • Presumptive Freestanding Clinic
  • Specific Requirements for Physicians
  • Physician Supervision Requirements
  • Special Concerns for Non-Physician Practitioners
• Incident-To Services for Hospitals
  • Hospital Payment For All Services Incident-To Physicians
  • Presumptive Provider-Based Setting
  • Physician Supervision Rules
  • Specific Impacts of Hospitals
• Physician Supervision
  • Change for Direct Supervision to General Supervision
  • Special Requirements for Freestanding Clinics
  • Special Requirements for Hospitals
  • Documenting Physician Supervision
• Associated Impacts of the Incident-To Concept
  • Provider-Based Rule
  • 3-Day Payment Window
  • RHCs
  • CAHs and Small Rural Hospitals
  • Telemedicine
• Case Studies

Who Will Benefit:-

• Coding, Billing and Claims Transaction Personnel
• Physicians
• Non-Physician Practitioners
• Health Information Management Personnel
• Patient Financial Services Personnel
• Outpatient Departmental Managers
• Provider-Based Clinic Nursing Staff
• Chargemaster Coordinators
• Provider-based Clinic
• Clinical Operations Personnel
• Internal Auditing Personnel
• Financial Analysts
• Revenue Cycle Specialists
• Compliance Personnel
• Cost Reporting Personnel
• Other Interested Personnel