Insurance is recouping funds.
What are my options?
This question comes up A LOT. Can a provisionally licensed person bill under a supervisors’ license. Is that fraud or is it okay?
The answer is maybe. Context matters in this situation.
Here are some things you need to consider to determine if you might be eligible to do this type of billing. First, let’s make sure we have common language as we discuss this topic. The process of one clinician providing services (usually the resident or provisionally licensed clinician) and billing under the supervisors credentials is called “incident-to” billing in the Medicare world.
What is “incident-to” billing? Incident-to services are defined as services that incident to physician or adjunctive to provider rendered services. This means that the services rendered are
Additionally, the part of incident-to services and billing that comes up most frequently for mental health professionals is when services are supervised by certain non-physician practitioners.
The services must be part of your patient’s normal course of treatment, during which a provider personally performed an initial service and remains actively involved in the course of treatment.
Note: The provider does not have to be physically present in the patient’s room while the services are performed but you must provide direct supervision. You must be present in the office to render assistance, if necessary. The patient record should document essential requirements for incident to service.