While reading an AAPC article https://www.aapc.com/blog/31665-lets…ing-incident-4
scenario 2 "A physician performs the initial evaluation, develops a diagnosis, and develops the care plan. Auxiliary personnel perform subsequent follow-up services. The physician, however, is not on the premises. Instead, an NP/PA supervises performance of the services by auxiliary personnel.

For this case — even if all other criteria under the incident-to rule were satisfied — the service cannot be legitimately reported under the name/NPI of the NP/PA. The most obvious reason is because the NP/PA did not initiate the care; therefore, the auxiliary person is not performing a service that is integral although incidental to the NP’s/PA’s professional service. As a result, the authority in the coverage rules for NPs/PAs, which are conditioned on compliance with §410.26, would not be satisfied.

Depending on your state, compliance with §410.26 requires that the auxiliary personnel are permitted under applicable licensure rules to perform the service under an NP’s/PA’s supervision. As delegation authority is not commonly found in most NP/PA licensure rules (and where it’s found, it’s extremely limited), it’s possible that such a delegation would not be permissible. As a result, the requirements of §410.26 would not be met."

This hit home to me because I have this situation. 1 coworker states ok to bill with the Dr. NPI as incidental because the PA can’t be the supervising physician, and other states because the PA didn’t initiate the initial evaluation they are disqualified as supervisor for the auxiliary massage therapist and to write the visit off. Help please…
Dena W. CPB