John Falcetano (john.falcetano@brooksrehab.org) is Director Corporate Compliance at Brooks Health System in Jacksonville, FL.

A critical element of any effective compliance program is monitoring. As a service to our members, each month this column focuses on potential monitors for specific business lines.

Incident-to billing is a way to bill for outpatient services that are provided by a non-physician practitioner (NPP) such as a nurse practitioner (NP), physician assistant (PA), or other non-physician provider. Incident-to billing allows the NPP to report services “as if” they were performed by a physician. Under Medicare rules, incident-to services are reimbursed at 100% of the fee schedule amount for the physician, and services provided by the NPP are typically reimbursed at 85% of the physician fee schedule amount.