Q&A: RHC "incident to" services

Q. How are “incident to” services defined for rural health clinics?

A. In general, “incident to” refers to those covered services and supplies that are integral, though incidental, to an RHC practitioner’s services and are the following (Medicare Benefit Policy Manual, Chapter 13, §§120, 140, 160, 2016):

• Usually provided in an outpatient clinic setting
• Usually included in the RHC all-inclusive rate (AIR) payment
• Performed by a staff member of the RHC in a medically appropriate time frame
• Generally furnished under the appropriate RHC practitioner’s direct supervision

“Incident to” includes a service or supply that is either provided without charge (e.g., routine supplies) or is included in the clinic’s total charge for the visit (e.g., venipuncture performed by a nurse or medical assistant) (Medicare Benefit Policy Manual, Chapter 13, §§120, 140, 160, 2016). More than one “incident to” service or supply can be provided as a result of a single visit with an RHC practitioner. Supplies that must be billed to the DME MAC are not included as part of the billable visit.

For more information, see The Essential Rural Health Clinic Billing and Management Guide.

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