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The analysis of any legal or medical billing is dependent on numerous specific facts — including the factual situations present related to the patients, the practice, the professionals and the medical services and advice. Additionally, laws and regulations and insurance and payer policies are subject to change. The information that has been accurate previously can be particularly dependent on changes in time or circumstances. The information contained in this web site is intended as general information only. It is not intended to serve as medical, health, legal or financial advice or as a substitute for professional advice of a medical coding professional, healthcare consultant, physician or medical professional, legal counsel, accountant or financial advisor. If you have a question about a specific matter, you should contact a professional advisor directly. CPT copyright American Medical Association. All rights reserved. CPT is a registered trademark of the American Medical Association.

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Therapy Services Billed Incident To

Who can provide therapy services other than physical, occupational, or speech therapists?

Therapy services can be provided to Medicare patients by physicians and non-physician practitioners (NPPs) such as nurse practitioners and physician assistants if all of the other coverage requirements for therapy services have been met.

What does therapy services provided “incident to” the services of a physician/NPP mean?

Therapists who are not enrolled in Medicare may provide therapy services to Medicare patients under the physician/NPP’s NPI.

Does the physician/NPP need to supervise the therapist?

Yes.  Therapists billing incident to a physician/NPP must be directly supervised by the physician/NPP, this means the physician/NPP must be on-site but not necessarily in the same room.

Can a therapist bill incident to another therapist?

No.  There is no coverage for services provided incident to the services of a therapist.  A therapist who is not enrolled in Medicare cannot bill under the NPI of a therapist who is enrolled.

Can assistants bill incident to a physician/NPP?

 No.  Assistants can only bill under the supervision of an enrolled physical or occupational therapist.  However, if a PT and PTA (or an OT and OTA) are both employed in a physician’s office, the services of the PTA, when directly supervised by the PT or the services of the OTA, when directly supervised by the OT may be billed by the physician group as PT or OT services using the PIN/NPI of the enrolled PT (or OT).

If the PT or OT is not enrolled, Medicare will not pay for the services of a PTA or OTA billed incident to the physician’s service.

Can other healthcare practitioners bill therapy services incident to a physician/NPP?

Regardless of any state licensing that allows other health professionals to provide therapy services, Medicare is authorized to pay only for services provided by those trained specifically in physical therapy, occupational therapy or speech-language pathology.

The services of athletic trainers, massage therapists, recreation therapists, kinesiotherapists, low vision specialists or any other profession may not be billed as therapy services.

Reference

Medicare Benefit Policy Manual

Chapter 15 – Covered Medical and Other Health Services

230.5 - Physical Therapy, Occupational Therapy and Speech-Language Pathology Services Provided Incident to the Services of Physicians and Non-Physician Practitioners (NPP)

About Us

Zachary Edgar JD, LLM is the managing partner for Therapy Comply.  Zachary is a healthcare attorney that specializes in federal and state healthcare regulatory issues particularly for physical, occupational, and speech therapy practices.  

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