Why Incident-To Billing & Timeframe Restrictions Matter in Podiatry
In podiatry, accurate billing is more than just a compliance requirement—it’s the backbone of a financially healthy practice. Many providers unknowingly put their reimbursements at risk by overlooking Medicare’s incident-to billing rules and timeframe restrictions on routine care services. This blog explains why these concepts matter and how to stay compliant.
Understanding Incident-To Billing “Incident-to” billing allows services performed by a non-physician provider (NPP), such as a medical assistant or nurse practitioner, to be billed under the supervising physician’s NPI for full reimbursement. However, certain conditions must be met:
- The physician must initiate the care plan.
- The physician must provide direct supervision (present in the office suite).
- The service must be part of the patient’s normal course of treatment.
Example Case: A podiatrist evaluates a diabetic patient and initiates a treatment plan for recurring nail debridement every 60 days. A nurse practitioner performs the service under direct supervision. If billed under incident-to rules and within the proper timeframe, Medicare reimburses the claim at 100%. Without supervision or outside the 60-day window without medical necessity, the claim may be denied or reduced.
Timeframe Limitations in Podiatry For routine foot care services like nail debridement (CPT 11720, 11721), Medicare imposes strict frequency guidelines. Typically:
- 11720: Debridement of 1-5 nails – allowed every 60 days
- 11721: Debridement of 6 or more nails – allowed every 60 days
Performing these services more frequently without documented medical necessity will result in denials.
Workflow to Stay Compliant
| Step | Task | Billing Solution |
|---|---|---|
| 1 | Track last visit and CPT code | Use EHR with alerts for timeframe conflicts |
| 2 | Document medical necessity | Justify need for early services in patient notes |
| 3 | Verify incident-to compliance | Confirm physician supervision and plan initiation |
| 4 | Submit claims | Include proper modifiers (if needed) |
How We Help Our billing service keeps your practice aligned with CMS regulations. We track CPT usage and timeframes and flag services billed too early. We also ensure incident-to rules are applied correctly so your claims are clean and compliant.
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