Nurse Practitioner (NP) or Physician Assistant (PA) Practicing "Incident to" Certifying Physician

The certifying physician for Therapeutic Shoes for Persons with Diabetes (TSPD) is defined as a Doctor of Medicine (MD) or a Doctor of Osteopathy (DO). A Nurse Practitioner (NP) or Physician Assistant (PA) can serve as the certifying physician if they are practicing "incident to" the MD or DO. "Incident to" requires that the NP or PA are practicing under the supervision of the certifying physician and all billing is under the certifying physician’s national provider identifier (NPI). The Centers for Medicare & Medicaid Services (CMS) provided guidance of diabetes responsibilities to NPs and PAs prescribing therapeutic shoes and inserts for persons with diabetes that can be found as a joint DME MAC article posted on November 5, 2020. This clarification is specific to NPs and PAs who are practicing under the supervision of an MD or DO (i.e., "incident to") and does not extend to NPs who practice independently (i.e., bill under their own NPI).

Additional information on "incident to" can be found in the CMS Internet Only Manual (IOM), Publication 100-02, Medicare Benefit Policy Manual, Chapter 15, Section 60 - Services and Supplies Furnished Incident to a Physician's/NPP's Professional Service.

Last Updated Mar 13 , 2024