CMS has rescinded Transmittal 87, CR 5288, which contained some extremely stringent requirements/clarifications to Medicare's "Incident to" policy. Key points included:
A practice or clinic must be physician owned and operated in order to bill Medicare for incident to services;
A requirement for very explicit and extensive documentation within the patient's medical record as it relates to the credentials of the treating personnel;
A patient care plan which contains details as to which services will be provided by a physician versus other healthcare provider, such as a nurse practitioner or physician assistant; and,
An actual authorization in the patient chart for services provided incident to the physician/NPP initial service.
To view the actual CMS document wherein Transmittal 87 is rescinded, visit http://www.cms.hhs.gov/Transmittals/downloads/R87BP.pdf.
You may view the original Change Request (CR) 5288 at http://www.cms.hhs.gov/ContractorLearningResources/downloads/JA5288.pdf on the CMS website.
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