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assistants, nurse practitioners, and clinical nurse specialists. (See §§150 through 200 for
coverage instructions for various allied health/nonphysician practitioners’ services.)
Services performed by these nonphysician practitioners incident to a physician’s
professional services include not only services ordinarily rendered by a physician’s office
staff person (e.g., medical services such as taking blood pressures and temperatures,
giving injections, and changing dressings) but also services ordinarily performed by the
physician such as minor surgery, setting casts or simple fractures, reading x-rays, and
other activities that involve evaluation or treatment of a patient’s condition.
Nonetheless, in order for services of a nonphysician practitioner to be covered as incident
to the services of a physician, the services must meet all of the requirements for coverage
specified in §§60 through 60.1. For example, the services must be an integral, although
incidental, part of the physician’s personal professional services, and they must be
performed under the physician’s direct supervision.
A nonphysician practitioner such as a physician assistant or a nurse practitioner may be
licensed under State law to perform a specific medical procedure and may be able (see
§§190 or 200, respectively) to perform the procedure without physician supervision and
have the service separately covered and paid for by Medicare as a physician assistant’s or
nurse practitioner’s service. However, in order to have that same service covered as
incident to the services of a physician, it must be performed under the direct supervision
of the physician as an integral part of the physician’s personal in-office service. As
explained in §60.1, this does not mean that each occasion of an incidental service
performed by a nonphysician practitioner must always be the occasion of a service
actually rendered by the physician. It does mean that there must have been a direct,
personal, professional service furnished by the physician to initiate the course of
treatment of which the service being performed by the nonphysician practitioner is an
incidental part, and there must be subsequent services by the physician of a frequency
that reflects the physician’s continuing active participation in and management of the
course of treatment. In addition, the physician must be physically present in the same
office suite and be immediately available to render assistance if that becomes necessary.
Note also that a physician might render a physician’s service that can be covered even
though another service furnished by a nonphysician practitioner as incident to the
physician’s service might not be covered. For example, an office visit during which the
physician diagnoses a medical problem and establishes a course of treatment could be
covered even if, during the same visit, a nonphysician practitioner performs a noncovered
service such as acupuncture.
60.3 - Incident To Physician’s Services in Clinic
(Rev. 1, 10-01-03)
B3-2050.3
Services and supplies incident to a physician’s service in a physician directed clinic or
group association are generally the same as those described above.