Coding for “Incident-to” Services

Final Thoughts

Attention to correct coding for incident-to services is particularly salient, as the Office of Inspector General (OIG) for the US Department of Health & Human Services has expressed concern that these services may be routinely coded incorrectly. Specifically, the OIG work plan for the 2013 fiscal year stated, “We will review physician billing for ‘incident-to’ services to determine whether payment for such services had a higher error rate than that for non–incident-to services.” The same report also cited a 2009 OIG review that found that “unqualified nonphysicians performed 21 percent of the services that physicians did not personally perform.”² In short, coding for incident-to services is under scrutiny, and it may be useful for dermatologists to review their internal policies regarding incident-to services.