No. Incident to services are limited to the office setting (place of service (POS) 11). However, if a provider establishes an office in a larger outpatient setting, the "incident to" services and requirements are confined to this discrete part of the facility designated as his/her office. 


  • Hospital-Based Physician (employees of the hospital)
    • The hospital is billing and "incident to" does not apply
    • Submit POS 19 or 22
  • Group of physicians (not employees of the hospital) and the office is confined to the discrete part of the facility
    • The physicians are incurring the expense and "incident to" would apply
    • Submit POS 11 (not POS 19 or 22)


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