Medicare billing is notoriously complicated, especially for psychiatry and behavioral health providers. One of the most misunderstood regions is incident billing – a policy most medicals have heard of, but some completely grasp. When applied correctly, incident-to billing can potentially increase reimbursement, enhance patient flow, and support mental health practices to operate more efficiently. This blog will help you explain what incident-to-illing means in mental health settings, why it matters, and who can use it.
What is incident to billing in mental health?
Incident to billing is a medicare policy that permits the facilities provided by qualified medical staff to be billed under a supervising practitioner’s National Provider Identifiers (NPI). Although the facilities are provided by another team member. Medicare pays the practices as if the supervising clinician personally conducted the visit, resulting in the complete repayment. The process works like this:
- The supervising provider- typically a psychiatrist, psychologist, NP, or physician – meets with the patient for the starting visit and establishes a detect and treatment plan.
- Follow-up visits that adjust within this plan might be done by another licensed provider on the care team.
- These follow-up facilities are billed under the supervision medical’s NPI rather than the person delivering the facilities.
Because the claim is billed under the supervising clinicians, Medicare repays at 100% of the physician’s fee schedule, compared with the 85% rate paid when NPs or PAs bill under their own NPI.
Core Rules For Utilizing Incident to Mental Health
In psychiatry and therapy settings, the most essential rules involve:
Surprisingly Clinician Must Initiate The Care Plan:
The initial visit should be conducted by the billing provider. If a new case arises later, the supervising provider must reassess the patient and update the plan before further incident-to visits occur.
Person Providing The Facility Must Be Properly Licensed:
Auxiliary personnel like NPs, PAs, psychologists, and social workers might perform the functions as long as they meet all state and federal scope needs.
Supervising Clinicians Must Stay Included:
Medicare no longer requires in-person presence for many mental health facilities. Under general anesthesia, the supervising medical staff are required to be available and direct care, even if they are not in the building.
Incident To Applies Only In Outpatient Medical Settings:
It can not be used in hospitals or skilled nursing services, where different Medical Billing Services rules apply.
Who Is Eligible For Incident To Billing?
- Qualified Auxiliary Personnel:
Complete licensed clinicians. MFTs and MHCs can now enroll and bill Medicare directly, but they might still provide incident-to services.
- Medicare Reconginized Superizing Practitioner:
Psychiatrists, physicians, NP, PAs, CNSs, CNMs.
- Billed under the physician’s NPI – 100% payment.
- Billed under NP/PA/NPI – 85% payment.
- Correct Supervision:
Generally, supervision is enough. Some facilities still need direct or virtual direct supervision.
- An Active, Documented Care Plan:
All facilities must follow the supervising provider’s established plan. New issues need a new evaluation by that provider.
- Proper Setting:
Permitted only in outpatient offices/clinics – not hospital or SNFs.
Incident to billing Vs. Supervisory billing
Although often confused, these two concepts are not the same. Incident to is a medicare billing rule, while supervisory billing generally applies to commercial plans and pre-licensed therapists working under licensure supervision. Medicare does not recognize pre-licensed therapists in private practice settings, so they can not participate in incident-to billing.
Book Docvaz Medical Company For Medical Billing Services!
Trust DocVaz to direct your practice through incidnet-to-billing the right way every time. Our theme confirms that providers adhere to every Medicare requirement – plan initiation, supervision rules, and correct coding – so medical clinics receive the complete reimbursement they deserve. With our expert team, psychiatrists and therapists can concentrate on patient care while we safeguard revenue, lower errors, and streamline workflows.
FAQ’s
Can an NP supervise incident to services?
Yes, if allowed by state law and medicare instructions
Does the supervisor need to be on-site?
Not for all the services permitted under the general supervision.
Can social worker associates or trainees bill incident-to?
No, only a complete licensed medical will qualify.
Can ADHA supplement adherence be billed incidentally?
Yes, if persistent with the supervising provider’s treatment plan.
What if it is billed incorrectly?
Medicare may deny claims, recover payments, or initiate audits.


