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Fam Pract Manag. 2013;20(3):43

Debra Seyfried is a former coding and compliance specialist for the AAFP and is currently an administrator in Kansas City, Mo. Kent Moore is senior strategist for physician payment for the AAFP. Author disclosures: no relevant financial affiliations disclosed. These answers were reviewed by members of the FPM Coding & Documentation Review Panel.

Immunization administration during preventive visits

"Incident to" charges for counseling

Section 60 of chapter 15 of the Medicare Benefit Policy Manual states that “auxiliary personnel” means “any individual who is acting under the supervision of a physician, regardless of whether the individual is an employee, leased employee, or independent contractor of the physician, or of the legal entity that employs or contracts with the physician.” Typically, auxiliary personnel are considered to be clinical staff such as nurses and technicians. Other Medicare-recognized nonphysician providers, such as nurse practitioners, physician assistants, and clinical nurse specialists, may also have their services covered “incident to.”

In general, “incident to” services and supplies must be:

  • An integral, although incidental, part of the physician's professional service;

  • Commonly rendered without charge or included in the physician's bill;

  • Of a type that are commonly furnished in physician offices or clinics;

  • Furnished by the physician or by auxiliary personnel under the physician's direct supervision.

You may want to confer with your local Medicare administrative contractor before submitting a claim for the “incident to” services you've described.

As for commercial insurers, you should check with each carrier to confirm your understanding of their policies. Some may allow “incident to” billing for such therapists.

Subsequent annual wellness visits

Editor's note: Some payers may not agree with the advice given. Refer to current coding manuals and payer policies.


Send questions and comments to, or add your comments below. While this department attempts to provide accurate information, some payers may not accept the advice given. Refer to the current CPT and ICD-10 coding manuals and payer policies.

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