Mohamed Nabulsi, Esq., Chair of Mandelbaum Barrett PC’s Healthcare Practice Group, shared key insights in the July 28, 2025 issue of Report on Medicare Compliance regarding the complexities and risks of incident-to billing in urgent care settings.
Commenting on a recent OIG settlement involving Diligent Urgent Care, Nabulsi explained why episodic care environments often don’t align with Medicare’s incident-to requirements — and how credentialing pitfalls and acute care dynamics can create compliance vulnerabilities.
“The acute nature of the encounter and nonrecurrent nature may preclude it from being suitable for incident-to billing,” he noted.
The article dives deep into billing practices, supervision requirements, and how regulatory shifts since COVID-19 have reshaped enforcement.
📖 Read the full article in Report on Medicare Compliance here.