The perils and perplexities of CMS’s incident-to billing rule
- January 11, 2024
In 1977, the term “Rural Health Clinic Services” was added to Section 1861 of the Social Security Act, which set out the basis for incident-to billing within the Medicare program. Although the regulation may seem straightforward, incident-to billing remains confusing to providers who may have compliance and repayment concerns if they improperly bill these services.
This article does not exhaustively discuss Medicare’s incident-to billing criteria or rules. Instead, it attempts to address certain problematic compliance concerns affecting physician practice groups and other healthcare entities billing the Center for Medicare & Medicaid Services (CMS) for services incident-to the physician’s service.
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