June 19, 2019
The Medicare Payment Advisory Commission (MedPAC) recently submitted its 2019 annual report on Medicare payment policy to Congress with recommendations on billing reform in primary care, creating better access including eliminating “incident to” billing.
“Incident to” billing provides an exception to the Medicare rule that stipulates services by non-physician practitioners—physician assistants, nurse practitioners, clinal nurse specialists, etc.—are only reimbursed at reduced rate, allowing 100% reimbursement. To qualify for the exception, services must take place in non-institutional settings and Medicare-credentialed physicians must initiate care.
“The Commission recommends eliminating ‘incident to’ billing for advanced practice registered nurses and physician assistants and refining their specialty designations to give Medicare a fuller accounting of the services provided by these clinicians and to improve policymakers’ ability to target resources toward primary care,” stated MedPAC in the report. “Policymakers may also want to explore a scholarship or loan repayment program for geriatricians to increase access to their services.”
MedPAC noted in the report that literature on “incident to” billing is limited, it conducted two analyses that suggested a significant number of services were provided by nurse practitioners and physician assistants and billed as “incident to” in 2016.
“Medicare’s ‘incident to’ rules and lack of specialty data create several problems, including obscuring important information on the clinicians who treat beneficiaries and inhibiting Medicare’s ability to identify and support clinicians furnishing primary care,” stated MedPAC in the report.
The report noted that when “nurse practitioners and physician assistants bill under their own national provider identifiers, Medicare and beneficiaries save 15% up front; when services are billed 'incident to,' Medicare receives no such savings.”
MedPAC recommended that Congress require advanced practice registered nurses and physicians assistants to bill the Medicare program directly and that the Secretary also refine Medicare’s specialty designations.
Medicare Payment Advisory Commission. Report to the Congress: Medicare and the Health Care Delivery System. 2019. http://www.medpac.gov/docs/default-source/reports/jun19_medpac_reporttocongress_sec.pdf?sfvrsn=0. Accessed June 19, 2019.