Incident-To vs. Split/Shared: Who Actually Gets to Bill That Visit?

Your nurse practitioner sees a long-time patient on a Tuesday afternoon, the claim goes out under the supervising physician, and Medicare pays 100 percent. Then the patient mentions a brand new problem, the NP handles it alone, and the claim goes out the exact same way. One of those visits holds up in an audit. The other one is an overpayment waiting to be found. In this video, I break down the Medicare rules for incident-to billing, split/shared visits, and billing under the NPP's own NPI: the six CMS requirements for incident-to, the new patient and new problem trap, whether the physician has to see the patient when the plan of care changes (and why a hallway consult isn't enough under Medicare contractor guidance), what changed with virtual direct supervision in the CY 2026 Physician Fee Schedule, the substantive portion test and modifier FS for facility split/shared visits, and exactly what your documentation has to show. FREE RESOURCE: Want the one-page Incident-To Readiness Checklist that goes with this video? Reach out through the contact form at http://help4docs.com and ask for the "Incident-To Readiness Checklist" by name. Need help with outpatient CDI, HCC risk adjustment auditing, or physician education? Visit http://help4docs.com Sources: 1. CMS, "Incident To Services & Supplies," Medicare Physician Fee Schedule, Advanced Practice Non-Physician Practitioners: https://www.cms.gov/medicare/payment/... 2. CMS Medicare Benefit Policy Manual, Pub. 100-02, Chapter 15, Section 60: https://www.cms.gov/Regulations-and-G... 3. 42 CFR 410.26 (incident-to services) and 42 CFR 415.140 (split or shared visits): https://www.ecfr.gov 4. CMS MLN MM14315, Medicare Physician Fee Schedule Final Rule Summary: CY 2026: https://www.cms.gov/files/document/mm... 5. Noridian Healthcare Solutions, JF Part B, "Incident To": https://med.noridianmedicare.com/web/... 6. CGS Administrators, J15 Part B, Medicare "Incident To" Provision fact sheet (revised September 22, 2022): https://www.cgsmedicare.com/partb/mr/... 7. WPS incident-to clarification, as reported by AAFP Family Practice Management (March 2016): https://www.aafp.org/fpm/blogs/gettin... 8. David M. Glaser, Esq., "Navigating Conflicting Guidance on Incident-to Services," RACmonitor (July 16, 2025): https://medlearn.com/racmonitor/navig... 9. HHS OIG, Prevalence and Qualifications of Nonphysicians Who Performed Medicare Physician Services (OEI-09-06-00430): https://oig.hhs.gov/reports/all/2009/... 10. Morgan Lewis, "Virtual Direct Supervision Allowed for 'Incident to' Medicare Billing and Other Telehealth Updates" (February 2026): https://www.morganlewis.com/blogs/hea... About the creator: Toni M. Appelberg-Parks, MBA-HM/LM, CVBA, CDEO, CDEI, CRCR, CPC, CSBI, CPPM, CPCO(c), President and Principal Consultant, Help4Docs. help4docs.com Does your practice bill incident-to, or do your NPs and PAs bill under their own NPI? Tell me in the comments. And if you have a coding, documentation, or compliance question, drop it in the comments too; I read every one. This video is for general educational and informational purposes only. It is not legal, compliance, coding, or billing advice for any specific patient, claim, payer, or organization. Coding, documentation, and regulatory requirements vary by payer and change over time, so always verify current requirements with your own organization's compliance team, legal counsel, and the applicable payer or regulatory guidance before making coding, billing, or compliance decisions. #IncidentTo #MedicalBilling #MedicalCoding #SplitSharedVisits #NursePractitioner #PhysicianAssistant #CDI #ClinicalDocumentationIntegrity #RevenueCycle #HealthcareCompliance #HealthcareEducation