Dermatology practices rely on physicians, non-physician practitioners (NPPs), and clinical staff to deliver efficient patient care. CMS’s 2026 policy provides greater flexibility for supervising eligible services remotely, but practices must still meet all applicable incident-to requirements.
That flexibility comes with an important distinction: the supervision requirement has changed, but the other incident-to billing requirements have not. Understanding which services qualify, how supervision will be provided, and what the medical record should demonstrate can help practices build a consistent workflow before claims are submitted.
Effective January 1, 2026, CMS permanently allows real-time, interactive audio-video technology to satisfy direct supervision requirements for eligible services. Audio-only communication does not qualify, and services with global surgery indicators of 010 or 090 are excluded.
The supervising practitioner must remain immediately available to provide assistance and direction throughout the service. Simply being reachable by telephone or agreeing to review the chart later is not sufficient.
The other incident-to requirements have not changed. The service must meet Medicare’s applicable criteria, including the relationship to an established treatment plan, the practitioner’s involvement, qualified personnel, setting, and supervision.
For example, an established patient returning for an eczema follow-up under a physician-established plan may qualify if all requirements are met. However, a new concern, such as a changing lesion requiring a new evaluation and treatment plan, should not be billed as incident to the physician.
Documentation should support the service provided, its relationship to the established treatment plan, and the required supervision.
When virtual supervision is used, practices should establish a consistent process for documenting the arrangement. Depending on the workflow, useful information may include:
Practices should also consider recording the HIPAA compliant technology platform and supervision start and end times also supports internal oversight.
These are recommended documentation practices, not universal CMS requirements for a specific template, connection log, or attestation. Documentation should be accurate, contemporaneous where appropriate, and consistent with the actual supervision arrangement.
A signed note alone does not establish that all incident-to requirements were met.
Medicare rules do not automatically apply to commercial payers. Requirements for incident-to billing, NPP credentialing, provider enrollment, and supervision may vary. Before implementing a workflow, verify each payer’s policies and applicable state requirements. A service that qualifies under Medicare rules may not qualify under a commercial payer’s policy.
If the measure does not start correctly, it often cannot be fixed later.
The OIG’s Medicare Part B Payments for Incident To Services project remains active on its Work Plan. The project examines whether Medicare payments for incident-to services complied with program requirements. This ongoing oversight reinforces the importance of reviewing supervision arrangements, supporting documentation, and billing practices. Medicare Part B Payments for Incident To Services | Office of Inspector General
Choose a common follow-up workflow and review it with your clinical and billing teams. Confirm that:
EHR Workflow Consideration: Ezderm's incident-to billing configuration is designed to support documentation and billing workflows for dermatology practices. Review your current processes to identify opportunities for greater consistency and efficiency.
Dermatology practices should periodically review their incident-to workflows, documentation practices, supervision arrangements, and payer-specific policies. A consistent process can help identify gaps before they result in claim denials, payment recoupments, or additional compliance concerns.
Accurate documentation and efficient billing workflows go hand in hand. Ezderm connects dermatology-specific charting, coding, and practice management tools to help your team stay organized and make informed billing decisions.
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