Incident-to billing refers to a Medicare arrangement where a supervising physician bills for services rendered by an NP or PA under the physician's NPI. Headway does not support this. Additionally, billing under another provider's NPI for services you did not personally render is not an incident-to issue — it is a misrepresentation of the rendering provider on the claim, which carries serious compliance and legal consequences.
If we have detected signs of incident-to billing on your Headway account, you will receive an email from Headway outlining clear next steps. We may ask that you:
- Transition any patients whose care you are not directly providing off your Headway account and calendar
- In cases where the rendering provider is also a Headway provider, and part of your group practice, that provider may bill sessions for these patients on their own calendar instead
- In cases where the rendering provider is not an active Headway provider, we are unfortunately unable to bill their claims at this time. Please ensure that these patients are either transitioned to a Headway provider, or are no longer having their sessions confirmed through Headway if care is being provided by a non-Headway provider
- Ensure that start/stop times confirmed on your calendar reflect the accurate start/stop times of each appointment
- Confirm which providers are rendering care to each of the current patients being billed through your account. We will be sending you a secure link shortly containing the relevant details - please respond to the email accordingly by the above date. This will help us ensure that we can continue to submit claims on your behalf in an accurate and compliant manner.
Headway currently cannot support incident-to billing.