Advancing The Profession of Pharmacy

Incident-to (Direct Supervision) vs. General Supervision for Consultant Pharmacists

by | Aug 3, 2018 | Consulting Pharmacist Education


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One of the most frequently asked questions I get about billing for pharmacist services is “Do I have to be in the physician’s office to bill for x, y, z-service?”

The easy rule of thumb is to know whether that service is beholden to the direct supervision (aka. Incident-to criteria) or the general supervision requirements.

When implementing a new service as a consultant pharmacist there are a few things to keep in mind regarding the supervision of auxiliary personnel.

1. Incident to billing criteria – direct supervision – under the same roof

These services must be performed under direct supervision – The physician must be in the office suite/building.

They cannot be billed when more than 50 percent of the visit is for counseling or care coordination.

They may not include diagnostic testing.

[examples of these billing codes with direct supervision requirements]

  • incident-to CPT codes for ambulatory care clinics 99211-99214
  • incident-to CPT code for skilled nursing facilities 99307 – 99318
  • Annual Wellness Visits

2. General supervision requirements – auxiliary personnel – may be offsite

These services may be performed under general supervision – The physician need not be on-site.

[examples of these billing codes with direct supervision requirements]

  • Chronic Care Management 99487, 99489, 99490
  • Transitional Care Management 99495 & 99496

3. Different Medicare Administrative Contractors (MACs) have different requirements regarding auxiliary or non-physician personnel.

Also check your state pharmacy practice act and the language around collaborative practice agreements


General supervision means the procedure is furnished under the physician’s overall direction and control, but the physician’s presence is not required during the performance of the procedure. Under general supervision, the training of the non-physician personnel who actually performs the diagnostic procedure and the maintenance of the necessary equipment and supplies are the continuing responsibility of the physician.

Direct supervision in the office setting means the physician must be present in the office suite and immediately available to furnish assistance and direction throughout the performance of the procedure. It does not mean that the physician must be present in the room when the procedure is performed.

Personal supervision means a physician must be in attendance in the room during the performance of the procedure.

What services are you dreaming of implementing in 2019?

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About the Author

Blair Thielemier, PharmD, is a business development consultant specializing in pharmacist-led billing models. She has set the industry standard for virtual pharmacy conferences with the Elevate Pharmacy Virtual Summit in 2017. She has consulted with national pharmacy organizations, drug wholesalers, point of sale companies, and Fortune 5 health insurers. She has books and online courses available for individuals looking to leverage their pharmacy knowledge into monetized clinical programs at She speaks internationally about trends in leveraging pharmacists to improve value-based care.


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