Shared visits vs incident-to billing for pharmacy services

Pharmacists deliver high-value cognitive services in the ambulatory care setting; however, lack of provider recognition under the Social Security Act restricts their ability to independently deliver billable clinical services and access reimbursement through national payers such as Medicare Part B. This often raises the question of whether the collaborative efforts of a pharmacist and a billing provider (eg, physician) during a patient encounter can be combined as a "shared visit" to bill for a higher level of service (LOS). However, a distinction must be made between shared visits and "incident-to" billing. In an incident-to model, in which a pharmacist sees the patient alone under billing provider supervision, the service can only be billed at the lowest level, 99211, according to Medicare as of 2026. Even when both a pharmacist and billing provider see the patient and contribute to the visit, the pharmacist's documentation cannot be used to determine the LOS because they are not a recognized billing provider; only the billing provider's documented work counts for billing purposes. However, this should not deter collaboration between pharmacists and other health care providers given the clinical benefits of team-based care. With evolving billing requirements tied to documentation of the billing provider, opportunities remain to establish sustainable collaborative care models despite limitations in leveraging combined pharmacist-billing provider documentation to increase LOS through a shared visit model.