Incident-to billing pays your rate for a therapist's Medicare visit
Use incident-to billing only for an established problem under your plan of care, while you stay involved. You don't need to be on site.
Co-founder, JotPsych
Your practice's therapist sees your Medicare patient between your visits. You'd like to bill the visit under your National Provider Identifier (NPI), at your rate.
WPS Government Services, “Mental Health Playbook: Incident To,” March 6, 2026, 57 minutes. https://www.youtube.com/watch?v=2eWt1xhV7kQ
WPS Government Services processes Medicare claims for Iowa, Kansas, Missouri, Nebraska, Indiana, and Michigan. The educator covers who can bill incident to, how to supervise, whether to co-sign, and what to do with a new problem.
Your therapist doesn't need to be enrolled in Medicare for an incident-to visit, but you do, a WPS educator says at 28:30.
- Keep incident to for established patients and problems. You see the patient first and set the diagnosis and the plan of care, the WPS educator says at 17:30. The therapist's visit follows your plan. New patients never qualify (6:30).
- Stay involved in the patient's care. Incident to isn't a transfer of care, the educator says at 18:30. For mental health, Medicare asks only for general supervision. You don't need to be on site, and the therapist can reach you by phone if needed, per Medicare's mental health booklet, page 25.
- Bill a new problem under the therapist's own NPI. New problems fall outside your plan, so incident to no longer applies, the educator says at 29:30. Your therapist can bill the visit if enrolled in Medicare, at the therapist's own rate. Without enrollment, no one can bill it (29:00).
- Put the supervising clinician on the claim. Only the supervising clinician may bill an incident-to visit, under federal rules. Co-signing isn't required. WPS still recommends it, as proof you stayed involved (26:00).
| Clinician who bills | Share of the fee schedule | Can bill incident to? |
|---|---|---|
| Physician | 100% | Yes |
| Clinical psychologist | 100% | Yes |
| Nurse practitioner, physician assistant, or clinical nurse specialist | 85% | Yes |
| Social worker, counselor, or marriage and family therapist | 75% | No |
Medicare's mental health booklet lists these shares. An incident-to visit pays at the supervising clinician's share, and an enrolled therapist who bills directly gets 75%.
Our view
Every incident-to claim depends on your plan of care. Date the plan. Name the diagnosis and how often the therapist sees your patient, and keep the plan with the therapist's notes in case of an audit.
JotPsych routes a supervised clinician's signed notes to your Co-sign Needed queue and records your co-signature on each.
Book 15 minutes- WPS Government Services, "Mental Health Playbook: Incident To," YouTube, March 6, 2026, 57 minutes. A WPS webinar held March 5, 2026.
- Centers for Medicare & Medicaid Services, "Medicare & Mental Health Coverage," MLN1986542, March 2026: payment by clinician type on pages 13 to 24; the incident-to provision and general supervision on page 25.
- 42 CFR 410.26, "Services and supplies incident to a physician's professional service", paragraph (b)(5): general supervision for behavioral health, and only the supervising clinician may bill. Read October 4, 2026.