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doi: 10.1002/mnfr.201400399

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However, the requirements are strict and frequently misapplied in pain management: The supervising physician must be physically present in the office suite (not just the building) during the service The billing physician must have established the patients plan of care in a prior visit The visit must be for a stable, established condition any new problem or significant change must be seen by the physician Incident-to billing is not allowed for hospital outpatient or inpatient settings, only in the office False Claims Act Risk: Billing incident-to when supervision requirements are not met can constitute healthcare fraud under the False Claims Act, potentially triggering liability of up to three times the amount of the false claim plus civil penalties