NP and PA Billing in 2027: When Incident-To Pays 100% — and When It Becomes an Overpayment

ONE VISIT. TWO PAYMENT RATES. THE DIFFERENCE IS EITHER EARNED OR OWED BACK.

When a nurse practitioner or physician assistant sees a Medicare patient in the office, the claim can be paid at 85 percent of the fee schedule under the NP’s or PA’s own NPI, or at 100 percent when billed incident-to under the supervising physician. That 15 percent difference is real revenue, and it is earned only when every incident-to condition is met on the date of service.

Most practices know the basics. The errors happen in the details: a new patient seen by the NP, a new problem added to an established visit, a change to the plan of care, a supervising physician who was not actually available, the wrong supervising NPI on the claim, or incident-to billing carried into a hospital setting where it does not apply. Each one turns a 100 percent payment into an overpayment, and once a practice identifies one, Medicare’s 60-day report-and-return obligation applies.

The rules keep moving. Since January 1, 2026, direct supervision can be met permanently through real-time audio-video technology, but not by audio-only, and not for services with a 010 or 090 global period. For 2027, CMS has put forward a new BC modifier for telehealth services furnished incident-to, a requirement that remote monitoring clinical staff be direct employees meeting every incident-to requirement, new advance care planning codes for clinical staff, and a change to how the G2211 complexity add-on is reported.

This practical session gives coders, billers and practice leaders a clear test for every NP and PA encounter: which billing path applies, what the record must show to support it, and how to find and correct incident-to errors before an auditor does.

Webinar Objectives

This webinar explains how Medicare pays for services furnished by nurse practitioners and physician assistants and how to choose correctly between direct billing at 85 percent, incident-to billing at 100 percent and split/shared reporting. Attendees will learn each condition that must be met for incident-to billing, the situations that disqualify a visit and turn the payment into an overpayment, and how virtual direct supervision applies in practice. The session also reviews the split/shared rules for facility settings, the 2027 changes affecting NP and PA services and incident-to billing, and the self-audit, documentation and repayment steps that protect a practice when errors are found.

Webinar Agenda

• Understand the three billing paths for NP and PA services and how each is paid
• Recall every condition that must be met before a service can be billed incident-to
• Recognize the scenarios that disqualify a visit from incident-to billing
• Identify the correct supervising practitioner and NPI to report on the claim
• Understand direct supervision, including virtual supervision by audio-video
• Discuss split/shared visits in the facility setting, the substantive portion and modifier FS
• Identify the 2027 changes affecting NP and PA services and incident-to billing
• Recognize how incident-to errors become overpayments and the 60-day report-and-return obligation

Webinar Highlights

• One Visit, Two Payment Rates: The 85 Percent vs. 100 Percent Decision
• Who Can Bill Directly: NPs, PAs, CNSs and Certified Nurse-Midwives
• The Physician-Initiated Course of Treatment Requirement
• Established Patient, Established Plan of Care
• New Patients and New Problems: Where Incident-To Ends
• When a Change to the Plan of Care Changes the Billing
• Direct Supervision and the Supervising NPI on the Claim
• Virtual Direct Supervision: Audio-Video Required, Audio-Only Excluded
• The 010 and 090 Global Period Exclusion
• Why Incident-To Does Not Apply in Hospital Settings
• Split/Shared Visits: The Substantive Portion by Time or Medical Decision Making
• Modifier FS and Facility-Setting Documentation
• The BC Modifier for Telehealth Services Furnished Incident-To
• Remote Monitoring Staff: The Direct-Employee Requirement
• Advance Care Planning Codes for Clinical Staff
• G2211 Reporting Changes for NP and PA Visits
• The 60-Day Overpayment Rule and How Extrapolation Multiplies Errors

Who Should Attend

• Medical Coders and Coding Specialists
• Medical Billers and Billing Managers
• Nurse Practitioners and Physician Assistants
• Clinical Nurse Specialists and Certified Nurse-Midwives
• Physicians and Supervising Physicians
• Practice Administrators and Office Managers
• Revenue Cycle Managers and Directors
• Charge Entry and Claim Edit Staff
• Denial Management and Accounts Receivable Specialists
• Compliance Officers and Compliance Managers
• Medical Auditors and Internal Review Staff
• Credentialing and Provider Enrollment Specialists
• Telehealth and Remote Monitoring Program Managers
• Hospital-Employed Practice and Multi-Specialty Group Leadership
• Billing Companies and Outsourced Coding Firms