How must services qualify to be considered "incident-to" when provided by a Non-Physician Practitioner (NPP)?

For services to qualify as "incident-to" when provided by a Non-physician Practitioner (NPP), they need to represent an expense that is directly related to the physician's practice. This requirement ensures that the services rendered are a part of the overall treatment plan established by the physician and that they are billed under the physician’s service.

The concept of "incident-to" services is designed to extend the physician’s ability to provide services through their staff while also ensuring that the services remain an integral part of the treatment plan for which the patient is already being seen by the physician. By being classified as a direct expense to the physician, it reinforces the notion that the supervising physician is responsible for the patient’s care, thereby allowing for appropriate billing under the physician’s National Provider Identifier (NPI).

It's important to keep in mind that while other factors such as supervision levels and insurance coverage can play roles in overall billing and reimbursement practices, they do not directly impact the definition of what constitutes "incident-to" services as mandated by Medicare guidelines.