Exploring the Dynamics of "Incident to" Billing Practices: Implications of Full Practice Authority for Nurse Practitioners

Abstract

Incident-to billing allows office services delivered by advanced practice providers to be billed under a supervising physician’s NPI, creating a payment wedge and potentially mismeasuring who produced care. Using 2020-2022 HealthJump EHR data from more than 4,000 office-based physician practice organizations, we link encounter-side and charge-side clinicians for the same hashed encounter to construct broad clinician mismatch and stricter advanced-practice-provider-to-physician mismatch measures. Among 10.7 million comparable billed office E&M records, broad mismatch affects about 14 percent of records annually and APP-to-physician mismatch affects 3.3 to 3.5 percent, with patterns concentrated across practices, persistent over time, increasing with provider-day throughput, and tied to meaningful dollar volume.