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“Incident to” services are defined as those services that are provided incident to physician professional services in the physician’s office (whether located in a separate office suite or within an institution) or in a patient’s home. To qualify as “incident to,” services must be part of a patient’s normal course of treatment, during which a physician performed an initial service and remains involved in the patient’s treatment.

As the profession of audiology has changed over the years, so has the recognition of the professional services provided by audiologists. One of the prime examples of this is the policy changes concerning “incident to” billing for audiology services. Audiology services must now be billed using the provider number of the audiologist who provided the service.

“Incident to” billing does not apply to audiology services provided by audiologists, though prior to 2003, many audiologists billed services that way. Changes in regulatory language from CMS in 2003 stated that services falling within their own benefit category could not be billed “incident to”. Audiology services fall under the category of “other diagnostic tests”. This was further reinforced in October, 2008 when audiologists were required to have their own NPI (National Provider Identification) numbers and be enrolled as Medicare providers. Services provided by an audiology technician or nurse, as permitted by state laws, can be billed using the physician’s NPI number, or “incident to”.

Available Resources on Topic

Medicare Benefit Policy Manual Chapter 15 Section 80.3 (search “Audiology Services”)

Q: I work in an ENT setting. My office manager insists that we should submit claims for diagnostic audiology services that I perform to Medicare using the physician’s Medicare number. Is this allowed?

A: No. All diagnostic audiology services billed by an audiologist must be billed using the audiologist’s NPI number. This is required regardless of who referred the patient to the audiologist.

Q: Are there any services that an audiologist can submit to Medicare as incident to?

A: Audiologists can perform the technical component (TC) of a code and bill this component incident to the physician as long as that code is

  1. Not defined by Medicare as an audiology service
  2. Not defined by Medicare as an “always therapy” service
  3. Is within their scope of practice and consistent with state licensure laws.

Q: Can an audiology assistant or technician bill services “incident to” an audiologist?

A: No. Services performed by an audiology assistant or technician cannot be billed incident to an audiologist.

Q: Can audiology or ototechs perform and bill 92557 incident to the physician?

A: No. Audiology or ototechs can only perform procedures incident to a physician if the procedure code has separate technical and professional components. In such cases, the audiology/ototech would bill the technical component only. CPT code 92557 is not divided into technical and professional components, so could not be billed incident to a physician by audiology/ototechs.

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