Opportunities to Increase Income
What is Incident to Physician Services, or “Incident to” services?
These services are provided by an additional person under the direct supervision of a physician or certain non-physician providers. Center for Medicare and Medicaid Services (CMS) further defines “incident to” services as commonly rendered without charge or included in the physician’s bill and furnished by the physician or by auxiliary personnel.
Are there opportunities for RDNs to do incident to services?
Yes, there may be in your practice area but there are restrictions and details.
Medicare
It is important to note that because RDNs are recognized as independent billing providers for MNT by CMS, MNT cannot be provided incident to physician services under Medicare.
Beyond MNT in Medicare
RDNs are not independent billing providers for the following benefits, but the RDNs may be qualified to provide all or a portion of an intervention when under supervision, depending on the service. As auxiliary personnel, RDNs may be employees or contracted employees.
Annual Wellness Visit
Cardiac Rehabilitation/Intensive Cardiac Rehabilitation
Chronic Care Management Services
Intensive Behavioral Therapy for Obesity
Intensive Behavioral Therapy for Cardiovascular Disease
Remote physiological monitoring services (e.g., glucose)
Other Health Plans
‘Incident to physician services’ impact dietitians with commercial as well as Medicaid plans differently.
in certain situations, medical nutrition therapy (MNT) can only be provided “incident to” a physician or other qualified billing provider
Registered dietitian nutritionists (RDNs) may be qualified to provide other services “incident to” a physician.
MNT as a component of Physician Evaluation and Management Services
The option of providing MNT as “incident to” Evaluation and Management Services (E&M) should only be considered when the client(s) have no insurance coverage for MNT. When physician/provider agreements and payer policies consider nutrition counseling within the scope of physician services, RDNs (who work in physician practices) could provide MNT as a component of a physician visit. There might be limitations regarding services provided “incident to,” such as rules prohibiting a billing provider from submitting two claims for the same diagnosis on the same day. It is important to confirm “incident to” policies with each insurer.
“Incident to” services may be advantageous
They allow RDNs to expand their scope of practice and position their services when marketing and negotiating. Thus, RDNs are able to provide both MNT independently and administer other services “incident to” a physician. This can increase the RDN’s practice income and attraction for fee-for-service or value-based payment arrangements.
Downside of ‘incident to’ services
Takes time to obtain clarification from each insurer how MNT and the other services are to be provided and billed.
When MNT is provided “incident to” rather than through MNT benefits, it could create a perception of decreased demand for MNT and thus lead to underutilization and even reducing MNT services from consumer health insurance benefits. When MNT procedure codes are billed by the RDN are not covered, but they are billed, the insurer is aware of need for services and the RDN credential is visible. Some insurers re-adjust policies for services desired by their members on an annual basis.
When MNT is provided “incident to,” the RDN will likely be invisible in health care data.(Historically, this contributed to a perceived lack of need or existence for MNT services in the previous decades).
Work with your biller and contractors to determine the financial benefits of working with primary and specialty care offices. Investigate the Academy resources as well as our personalized coaching. www.mntreimbursement.com