Staying compliant with Medicare’s billing and supervision requirements is essential for every physician practice, not only to protect revenue but also to ensure proper documentation and audit readiness.

In October 2025, Noridian Healthcare Solutions released updated guidance on “Incident To, Supervision, and Non-Physician Practitioners (NPPs)”, clarifying how these rules impact daily operations, from staffing and scheduling to billing and coding.

While the full presentation dives deep into regulatory detail, here’s a high-level overview of what practices should know.

The Basics:  What “Incident-To” Means

“Incident-To” allows services performed by your clinical staff or non-physician practitioners (NPPs) to be billed under a supervising provider’s NPI, but only when specific supervision and documentation requirements are met.

Understanding the correct use of “incident-to” ensures accurate reimbursement and prevents compliance issues during payer audits.

Supervision and Split/Shared Rules at a Glance

• Supervision levels (direct, general, and immediate) define how available the supervising provider must be during patient care.
• Split/shared services apply to facility-based E/M visits when both a physician and an NPP share responsibility for the encounter.
• The provider who performs the “substantive portion” (more than half the total time or majority of medical decision-making) should bill the visit.
• Virtual supervision continues to be allowed through December 31, 2025, under current CMS policy.

Why It Matters

Accurate understanding of these distinctions helps practices:

• Improve billing accuracy
• Reduce compliance risk
• Streamline provider workflows
• Ensure full reimbursement for services delivered

Even small errors in supervision level or documentation can lead to denied claims, reduced payments, or audit exposure.

Learn More

For a full breakdown of these guidelines, including definitions, documentation examples, and references to CMS and the Code of Federal Regulations, view the complete Noridian Healthcare Solutions presentation here: Incident-To, Supervision, and NPPs (October 2025) 

Partner with Peregrine Healthcare

At Peregrine Healthcare, we help practices strengthen compliance, improve collections, and optimize every step of the revenue cycle. From coding audits to front-office efficiency reviews, we help you protect what you’ve earned and uncover hidden opportunities for growth.

Request a complimentary revenue cycle review at 877-463-1110 or visit peregrinehealthcare.com.