THE FRONT-DESK ARTIFACT · MEDICARE PART B
“Can this be billed incident‑to?”
The question that decides more mental health revenue than any other. Five questions, walked in order, before the patient reaches the room. Any single “no” ends the walk. These are Medicare’s rules; commercial payers and Medicaid plans write their own, and the payer’s manual governs.
FIVE QUESTIONSANY NO ENDS THE WALKOFFICE SETTINGSIGNED 07 · 2026
1
THE PATIENT
Has the physician seen this patient and initiated care for this problem?
No — not incident-to. The physician performs the initiating visit first; new patients are never incident-to.
YES · CONTINUE
2
THE PLAN
Is today’s service part of the physician’s established plan of care?
No — not incident-to. Your service must carry out the plan the physician set, not a new one.
YES · CONTINUE
3
THE PROBLEM
Is the visit limited to that established problem, nothing new raised?
No — a new problem needs the physician. They see the patient and set a new plan before incident-to resumes.
YES · CONTINUE
4
THE PLACE
Is this the office, not a hospital or facility setting?
No — incident-to lives in the office. Facility settings run under different rules.
YES · CONTINUE
5
THE SUPERVISION
Is the supervising provider in the office suite right now, available to help?
No — not incident-to today. Direct supervision means present in the suite during the visit — not on call, not on video.
FIVE YES ANSWERS · VERDICT
Incident-to holds. Bill under the supervising provider.
Document who supervised, from where, and against which plan of care. And if you hold a full LPC or MFT license: you may also bill Medicare directly under your own NPI, as counselors have since January 2024, sometimes the cleaner route.
MEDICARE PART B ONLY · COMMERCIAL AND MEDICAID PLANS SET THEIR OWN RULES · YOUR MAC GOVERNS
FOR THE FRONT DESK
The printable version, signed and dated.
One page, made to be pinned where the scheduling happens. Enter your email and it opens ready to print. You’ll get one note when the rule moves and the sheet needs replacing.
This tree is dated for a reason. The app tells you the moment any branch moves.
Join the pilot →