Question
We are getting a lot of nurse practitioners and physician assistants being added to the practices does anyone have good articles on what they can and can not bill and when to use incident to and when to bill under themselves.
I do understand incident to physicians have to be on site etc… but can a nurse practitioner do services without the physician readily available and bill under their ID alone . Can they supervise infusion? Can they see new patients without physicians being any part of it?
Answer
Guidance for “Incident to” Billing under Center for Medicare & Medicaid services (CMS)
Incident To Services & Supplies | CMS
Question
We have started offering Keytruda Qlex prior to having a permanent HCPCS code. We are experiencing some challenges with reimbursement from various payers with the temporary HCPCS codes. I'm reaching out to get some guidance on this topic.
Answer
Temporary or miscellaneous codes trigger manual review because Payers can’t auto-adjudicate claims without a permanent J‑code.
This is normal for new oncology products and new formulations of existing drugs like Keytruda.
Depending on the product’s status, payers may require:
If different payers require different codes, you may need payer‑specific billing sheets.
Most payers require:
This is often the single biggest factor in getting claims paid during the temporary period.
Many plans publish temporary billing instructions for new oncology products. These may include:
If you haven’t already, it’s worth reviewing your top payer interim billing instructions.
Because claims are manually reviewed, documentation matters more than usual:
This reduces denials for “insufficient information.”
Most organizations see a spike in denials until the permanent code is active. Appeals should include: