Clearing Up “Incident To” Billing Confusion. Gaining Clarity In Private Practice

“Incident To” "Supervisory" Billing Confusion

Posted by  Kym Tolson, Billing Expert, Traveling Therapist

Are you confused about the rules governing your ability to bill under the license of another professional?

You aren’t alone. The fear of mistakenly committing fraud keeps many therapists from tapping into their income potential. However, if you can define the terms, clearly, obtain some up-to-date information, and learn the ropes from a trustworthy guide, you might feel differently.

Let’s explore “incident to” billing together.

“Incident To”…What Are We Really Talking About?

Typically, the phrase “incident to” refers to the relationship between a conditionally licensed person and their fully licensed supervisor.

Let’s say you want to provide sessions that are covered by a client’s insurance. How can you do this if you work under a supervisor’s umbrella?

Essentially, if you meet the appropriate requirements you can legally meet with clients and get paid to do so. Still, context is important for getting things right on your claims. Below, we break down what’s legitimately allowable for you to bill and how to do so.

As the supervisee, incident-to billing allows you to:

  • offer mental health services that are commonly provided in a therapist’s office.
  • provide services that are integral, though incidental, parts of your supervisor’s professional offerings.
  • conduct sessions without your supervisor in the room. However, the supervisor legally still facilitates by remaining on location throughout your appointment. The supervisor then reviews the session notes afterward.
  • provide sessions that are a normal part of the client’s course of treatment. However, it is important that the supervisor personally performs an initial service and remains available throughout treatment.
Incident to billing
Incident To Billing

Investigate the Insurer… Are You Sure You Are Cleared to Claim?

This is important. To successfully bill, you must take time to be sure you know the incident-to billing parameters of your location.

Your state and insurance carrier matter greatly. Why? Each plan operates differently in each state. Cigna is the only insurer that has a blanket policy that allows for national application.

So, to be clear, Medicare often permits incident-to billing. Unfortunately, many private plans don’t. Figuring out whether you can bill under your supervisor’s credentials is best accomplished by reaching out directly.

First, contact each insurance panel. Then discuss with the appropriate parties which incidental, supervised services are permitted under their policy. From there, you can determine if you are eligible for this type of billing and which requirements hold true for you and your state.

Pro tip: Go to Psychology Today, look up limited licensed providers in your area, see what insurances they take. That will help pinpoint some insurance plans that allow provisionally licensed providers to bill under their supervisor. Unlikely to falsely advertise, they have already done the research that will point you in the right direction.

Take On The Billing Process…What Do You Actually Do?

Okay, so what does billing look like?  First, remember that your supervisor (the attending provider) must see the patient first( though not on every visit). They provide oversight, engagement as needed. With that understood, you are fine to meet with the client.

After seeing the client, you will enter the appropriate billing codes and sign the form appropriately for the plan. Your supervisor will then review your submission and approve it and submit it to the billing department for review.

As requirements vary state to state and payer to payer, you are responsible for ensuring the submission of correctly formatted claims. For example, some policies will ask that your name be provided along with your supervisor’s credentials. Others will require your supervisor’s name and credentials instead. Here is a list we are compiling in my Facebook group, "Insurance Billing For Telehealth Providers"

Don’t Bill Alone

With good information and support, you can do this and feel confident about moving forward. Soon, sustaining your income legitimately without concerns about fraud will be entirely possible. Any fear of creating problems for you or a supervising professional will also no longer worry you. Let’s talk soon and put our heads together. I’m here to assist in making worries about incident-to billing a thing of the past.

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