Decoding incident-to and provider-based billing: ensuring payment and avoiding liability

In this increasingly complex world of Medicare reimbursement, physicians must constantly review their billing practices to ensure compliance with all Medicare requirements. "Incident-to" billing and provider-based billing are two areas that present unique challenges for providers, especially those practicing in hospital-owned practices such as hospital outpatient departments. Both incident-to and provider-based billing limit providers' abilities to bill for and receive reimbursement in those practice settings. The Office of Inspector General's 2012 Work Plan Report identified both incident-to billing and place-of-service errors as two of the many areas for investigation and compliance efforts in 2012. This article focuses on identifying the unique point-of-service challenges presented by physicians practicing in hospital outpatient departments or hospital-owned clinics.