CMS Chief Affirms Incident-to Billing for Pharmacists is Allowed

Marilyn Tavenner, administrator for the Centers for Medicare and Medicaid Services (CMS), wrote the American Academy of Family Physicians (AAFP) in March that Medicare Part B regulations do allow physicians to bill the program for services provided by pharmacists in an outpatient setting so long as the pharmacist’s services are provided incident to a physician’s care.

The AAFP had asked the CMS for confirmation that incident-to billing is allowed.

Tavenner added in the letter that the services provided by the pharmacist must meet Medicare’s conditions as to what constitutes incident-to professional services. It also must be allowable under a particular state’s laws on the matter.

In a nutshell, the affirmation allows a doctor to bill for some of the healthcare services provided by his practice staff members so long as the services provided are part of an already established patient care plan. Since many physicians’ practices today include the services of a pharmacist, the pharmacist’s services now may be allowed in the physician’s billing to Medicare.

Billable services provided by a pharmacist could include the pharmacist’s review of applicable patient history, counseling regarding the benefits and risks of prescribed medications, as well as instructions to patients on how to improve their pharmaceutical treatment outcome.

The letter from AAFP to CMS requesting clarification included the following statement:

“We (the AAFP) cannot find anything in section 60 that would exclude pharmacists from this definition…accordingly, we are inclined to think that physicians may bill Medicare for a Part B covered service provided by a pharmacist in the practice as long as all of the incident-to rules are otherwise met.”

In her reply to the AAFP, Tavenner said that CMS agrees with the AAFP’s “impression that if all requirements of the ‘incident to’ statue and regulations are met, a physician may bill for services provide by a pharmacist as ‘incident to’ services.”

For more information on Tavenner’s clarification, read a May blog post by CarePharmacies.com. You also may read an ASHP article on it.

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