UCR 239: Incident To billing for a hospital-employed urologist at a freestanding clinic, Incident To Target Probe and Educate (TPE) Audit, and correct coding for ASC stent removal without cystoscope

April 18, 2025 

Scott, Mark, and Ray discuss questions that came into the PRS Helpdesk:

1. For the past 8 months, I have been in an employed position with a county hospital system that provides inpatient and ambulatory services. Their coding consultants (acsteam.net) are telling the hospital that foley catheter insertions, bladder irrigations, and a list of other procedures commonly performed in urology clinics cannot be billed if they are not performed personally by the physician according to CMS. They reference a list of procedures from CMS and state that these services cannot be billed when performed by ancillary staff regardless of the level of supervision. They use https://www.cms.gov/status-indicators as their source citing the section on PC or TC indicators. Can this be true? Is it possible that this consultant is giving advice from a hospital perspective and not aware of differences between the ambulatory setting? The urology clinic I am working in is not a department of the hospital. It is freestanding. I have never worked in a clinic that did not bill for these services performed by ancillary staff with physician supervision.
2. I look forward to your response.
3. Good afternoon, my question is regarding "Incident to" required documentation. When we attended your seminar this past December, on Day 2, the new "Incident to Rule" was discuss. Can you please help clarify the new rule? My notes are not clear.
   We are in the process of CMS Review -"Targeted Probe and Educate Round 1". The letter states we were chosen for review because of being in the 60th percentile for our jurisdiction for code 99214.
   Our practice has the challenge of servicing and underprivilege community and estimated population of 590,142. We have 7 Urologist, 4 Apps and 1 Radiation Oncologist in our practice. Hence our volume is overwhelming.
   Earlier this year we submitted a batch of approximately forty records. Today we received a notification request "Incident to documentation: needed 2 previous office visits done by MD to support physician/supervising provider's initiation and continued involvement in treatment, and documentation to support direct supervision met.
   I appreciate any assistance with clarifying the “Incident to” rule.
   Thank you in advance for your assistance.
4. Doctor did a stent pull in the ASC but not with Cysto scope. How would we go about billing this?

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