INCIDENT TO BILLING  The intent of this bulletin is to clarify Insurance requirements for billing “Incident To” services (services rendered by a licensed/certified professional but directed by and billed under the NPI of a supervising practitioner).

USING THE SA MODIFIER “Incident To” services are also relevant to services performed by auxiliary personnel working within the scope of license (nurses, technicians, and therapists) and supervised by certain non-physician practitioners (APPs) such as physician assistants, nurse practitioners, clinical nurse specialists, clinical psychologists, and others. These services are subject to the same requirements as physician-supervised services. To qualify as “Incident To”, services must be part of
the patient’s normal course of treatment, during which a physician personally performed an initial service and remains actively involved in the course of treatment.

The physician does not have to be physically present in the patient’s treatment room while these services are provided, but must be available on site to provide supervision to render immediate assistance, if necessary. The SA modifier should be appended on “Incident To” claims rendered by any of the APPs listed below.

The use of this modifier should occur on each line where INCIDENT TO billing occurs.

• Physician Assistant (PA)
• Clinical Nurse Specialist (CNS)
• Nurse Practitioner (NP)
• All Master’s prepared behavioural health therapists, including Licensed Clinical Social Workers (LSCWs)
• Licensed Social Workers (LSW)
• Licensed and Associate Marriage and Family Counsellors,
• Licensed Professional Counsellors,
• Certified Register Nurse Practitioner PCP and Specialist (CRNP)
• Certified Registered Nurse Anaesthetist (CRNA)
• Certified Registered Nurse Psychiatric Mental Health Nurse