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Medicare’s reassignment rule gives an enrolled physician access to the claims a practice submitted for services that physician furnished and reassigned. You may know what happened in the exam room and still need to see what the practice told Medicare. The claim connects your work to the National Provider Identifier used, the service represented and the government money requested.
Under Medicare’s reassignment rule, an enrolled physician who furnished and reassigned services has a right to see the claims the practice submitted for that work. We work through that access with you, connecting the services you provided to what the practice billed. If the practice has brushed aside your questions about those claims, that is something to discuss with us too.
Reassignment lets an eligible organization or group submit claims and receive Medicare Part B payment for services you provided as a member. The practice may receive the money, but the service remains connected to the practitioner who furnished it. Your enrollment, the practice’s billing role and the services at issue are where we start with you.
The Centers for Medicare & Medicaid Services records the reassignment relationship in its enrollment forms. The December 2025 group enrollment form identifies the practitioner, the organization and the effective date, and covers new, changed and terminated reassignments. Those details connect a physician to a particular billing entity over time, so the history matters when we examine older claims.
An NPI registry entry identifies the provider. A submitted claim shows what someone asked a payer to reimburse. The Centers for Medicare & Medicaid Services describes the registry in its Medicare Provider Enrollment guidance as a directory displaying public information such as a provider’s name, specialty and practice address.
The physician and the business can occupy different roles in the same payment relationship. For certain imaging, laboratory and durable medical equipment orders, the ordering professional’s identity and enrollment or valid opt-out status also matter. A directory entry cannot supply the treatment history or the supervision facts behind the claim.
The useful comparison places the submitted claim beside the service date, payer, schedule, medical record and actual practitioner. The treatment record describes the care and its author. Staffing and supervision records help explain who performed the service and who was responsible for supervising it. We examine how those facts became the claim the practice submitted.
The billing entity, rendering practitioner, ordering professional and supervisor describe different roles. Under incident-to billing, a nurse practitioner’s visit can go out under the supervising doctor’s name when the service meets the requirements for that billing. The review needs both the name used on the claim and the work supporting that use.
The remittance shows Medicare’s response to the submitted claim, including a payment denial. The Medicare claims manual describes denial messages on the physician’s remittance notice. We compare that response with the claim and the care: what the practice asked for, how Medicare treated it and what actually happened in the exam room.
The comparison also reaches the service itself. An inflated visit level concerns how much work the claim represents, while a fabricated reason for treatment concerns the clinical basis for payment. Those questions belong beside practitioner identity when the chart and claim tell different stories about the same encounter.
False incident-to billing can claim a physician’s identity and payment rate for work that does not meet the conditions for that attribution. The conditions include the initial personal service, continuing involvement in treatment, eligible personnel and appropriate supervision.
There is money in that distinction. Direct nurse practitioner and physician assistant claims generally use an allowance of 85% of the physician fee schedule amount, while qualifying physician-supervised incident-to services can use the physician allowance. The claim’s attribution can therefore change what the practice receives for the encounter.
For applicable services, the 2026 supervision rule allows a doctor to supervise through live video, rather than audio alone. The other incident-to conditions still apply. The service date, setting and kind of supervision are part of the claim comparison, so we examine what the particular service required and what supervision actually occurred.
Physician billing cases show how the submitted identity can diverge from the care. The distinction becomes concrete when the claim is compared with travel, treatment and record changes inside the practice.
Pain Specialists, a New Jersey pain clinic, pleaded guilty to health care fraud. In its account of the criminal case, the Justice Department described the practice using its physician owner’s NPI while he was traveling and absent from the clinic. Under the requirements then in force, the services required his personal consultation or direct supervision of the person providing them.
The travel dates mattered because of what the billed services required at that time. The practice’s claims attributed work or supervision to the physician while he was elsewhere. We see the problem plainly: the bill put the physician in a role he was not there to perform.
Orange Medical Care and its physician owners agreed to pay $600,000 in 2024 to resolve Medicare and Medicaid billing claims. They admitted submitting claims naming the owners as rendering providers when other practitioners had performed the services. Those practitioners had not enrolled in Medicare or Medicaid, and on many occasions the owners had no personal involvement or supervision.
They also admitted altering patient records to make it appear that an owner had seen the patient. That detail matters to us: a chart changed to match the bill can conceal the very mismatch a physician is trying to understand. The government joined a whistleblower’s case. The HHS Office of Inspector General investigated, with New York’s Medicaid Fraud Control Unit collaborating in the investigation and resolution.
Sparrow agreed to a 2023 settlement of incident-to billing allegations. The government alleged that the health system billed services under a physician’s name and rate when advanced practice providers had furnished them without meeting the incident-to criteria. The whistleblower’s complaint described what chart review allegedly revealed:
In the course of those reviews, she found medical charts from across the healthcare system where non-physicians were examining patients for new complaints and billing under the doctor’s name in violation of the “Incident to” rules.
The allegation reaches the treatment relationship behind the billed name. The initial physician service and the course of care give the chart reviewer a different question from whether the physician’s NPI appears correctly on a form.
For claims billed under a physician’s NPI, useful evidence connects the submitted service to the actual work and the people who controlled its billing. A physician can explain the care and supervision. A scheduler may know who was working, and a billing employee may know whose instructions determined the identity used on the claim.
The Journal of AHIMA’s 2017 article, Busting Bad Medicine: a Call to Action Addressing Healthcare, Fraud, Waste, and Abuse, pairs documentation with witness knowledge. It discusses treatment dates, treatment descriptions and signatures, then explains that fraud investigators also need trustworthy witnesses who can tell them what they know.
An insider’s account can explain why the claim carries a particular name, who changed a record and what happened after someone questioned the billing. That is what a directory search leaves out: the decisions inside the practice.
Knowingly false physician billing to government health care programs can support a False Claims Act case. Orange Medical shows how the practitioner identity, altered records and government reimbursements can come together in a case begun by a whistleblower. We work with you to connect what you know about the practice to the claims and the decisions behind them. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers.
If the services billed under your NPI do not match the care or supervision you know occurred, talk with our whistleblower experts about the practice behind those claims. We work beside you to build the case from the clinical encounter through the billing decisions and bring in healthcare fraud whistleblower lawyers who know physician practice claims. Speak to us about the claims going out under your name and how we can build your strongest physician billing whistleblower case.