Physical Therapy Incident-to Billing Guidance

Evaluation and Management Coding for Physical Medicine and Rehabilitation

Incident-to services are services performed that are integral to and an incidental component of the physician’s professional services in an outpatient setting. Such services can be services performed, where permitted by the physician’s licensure rules, by auxiliary personnel, which may Include the physician’s staff.

For example, a chiropractic assistant applying electrical stimulation pursuant to the physician’s order and under that doctor’s direct (on-premise) supervision. While incident-to services are commonly performed by mid-level providers known as NPPs such as physician assistants (PAs), advanced registered nurse practitioners (ARNPs), and certified nurse midwives, for Medicare purposes, “auxiliary personnel can be anyone from an assistant to another physician provided that the ordering/supervising physician’s license permits delegation of the service that is performed by auxiliary staff.”

“auxiliary personnel can be anyone from an assistant to another physician provided that the ordering/supervising physician’s license permits delegation of the service that is performed by auxiliary staff.”


To bill services incident to, the physician must have initiated the care by personally performing the examination and personally developing the diagnosis and the plan of care. Auxiliary staff may perform services ordered where such delegation is permitted under the doctor’s license, provided that the physician is in the office suite providing supervision.

The physician does not need to be in the room, but they must be in the office and immediately available to intervene if needed. For physical and occupational therapists, the rule Is slightly different. Where permitted by their licensure rules, certified assistants can provide direct patient care under the supervision of a licensed PT/OT pursuant to a plan of care developed by the physical or occupational therapist and approved by a
medical physician.

Physical Therapy Incident-to Billing Guidance – Carenodes

Physical Therapy Incident-to Billing Guidance – Carenodes

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