Billing of Incident-to Services by Ancillary Staff

Title: Billing of Incident-to Services by Ancillary Staff
Standard #:


Issued: 08/21/2000 Reviewed/Revision Date: 10/06/2009, 05/06/2011, 12/09/2014


Medicare will reimburse a physician for services and supplies incident-to the service of the physician.  These services are billed under the physician’s provider number when the services are rendered “incident-to” the physician’s professional services.

In order for services or supplies to be billed “incident to”, they must be:

  • Service rendered to an established patient;
  • Service rendered in an office setting (POS 11);
  • An integral, though incidental, part of the service of a physician in the course of diagnosis or treatment of an injury or illness;
  • Commonly furnished without charge or included in the bill of the physician.
  • Furnished under the direct supervision of the physician (i.e., the supervising physician must be present in the office suite and immediately available to furnish assistance and direction throughout the furnishing of the procedure or supply but need not be present in the room where the procedure or supply is furnished)

The person furnishing the service must act under the direction of the physician, and may be either an employee or independent contractor of the physician or the entity that employs or contracts with the physician.  Services performed incident-to a physician’s professional service include services ordinarily performed by a physician’s office staff person (i.e. blood pressures, giving injections and changing dressings) but also services ordinarily performed by the physician such as setting casts and simple surgery.

All services billed under the incident-to provisions will be submitted on the CMS 1500 form under the supervising physician’s billing number.  The billing provider must review and co-sign the encounter documentation for services rendered.

* See standard B-411 for guidance regarding billing for non-physician practitioners (NP or PA).

Questions regarding policies, procedures or interpretations should be directed to the USC Office of Culture, Ethics and Compliance at (323) 442-8588 or USC Report & Response at (213) 740-2500 or (800) 348-7454.