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Home > Curriculum > Billing for Mid-Level Providers

Billing for Mid-Level Providers

Documentation requirements and compliance guidelines

21% of incident-to services were performed by unqualified personnel, according to a recent CMS audit report.

The OIG (Office of Inspector General) is taking a closer look at the qualifications of clinicians and the delivery of services billed incident-to supervising physicians under CMS' incident-to billing rules.

CMS defines incident-to services as those that are "furnished incident-to physician professional services in the physician's office (whether located within a different office suite or within an organization) or in the patient's home. Certified PAs and NPs may provide covered services to Medicare beneficiaries in accordance with their state scope of practice under state law and corresponding supervision/collaboration requirements.

5 Reasons to Attend

1. Mid-Level Provider claims are a common audit risk area.

2. Detailed review of the "physician supervisions rule" for proper incident-to billing

3. Explanation of documentation guidelines for incident-to services and episodes of care

4. Learn when it is appropriate to bill under the provider initializing care or under the supervising providers.

5. Ensure compliant billing procedures and reduce audit risk.

Get answers to tough billing situations with concrete examples and guidance on documentation needed to support mid-level provider claims.

Program Highlights

  • Incident to billing criteria, requirements and reimbursement considerations
  • Direct vs. indirect supervision by the physician/NPP
  • Level of education, scope of practice and other protocols of the NPP
  • State definition of scope of practice for mid-level providers
  • Differentiating between scope of practice and scope of licensing requirements
  • Examples of non-physician practitioners and auxiliary personnel
  • Explanation of service settings such as unsupervised or off-site
  • Difference between Nurse Practitioner and Physician Assistant
  • Guidance on which national provider identifier (NPI) to bill claims under
  • Review E/M documentation guidelines
  • Why CMS recovery auditors are scrutinizing practices that employ mid-level providers
  • Working with NPPs under independent contract agreement
  • Question and answer period to address participant questions

Who Should Attend

This program is designed for coders, auditors, providers, and clinical and practice staff involved in medical coding. Consultants, compliance officers, and office managers may also benefit.


The content covered in this course assumes a basic to intermediate understanding of third-party billing for outpatient services.

What to Bring

A program manual will be provided. No supplementary materials are required for this course.


Billing for Mid-Level Providers

Program Schedule

There are no live classes available at this time. See below for more options.

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    Continuing Education Units (CEUs)

    PMI CEU APPROVED Earn 3 PMI CEUs for attendance at this program. Practice Management Institute grants CEUs for its certified professionals based on total number of instructional hours (1 CEU per hour of classroom instruction). CEUs may be applied to annual recertification requirements, as directed in the certification renewal requirements for your credential(s).

    If you are seeking CEU credits for other certifications or organizations, please contact your organization for pre-approval and credit guidelines. A certificate of attendance will be provided.

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