No. In order for the service to qualify as "incident to," an initial encounter must have occurred between the physician and the patient, and a course of treatment established by the physician. In this situation, services performed by the PA do not meet the “incident to’” requirement and would not qualify because this is a new patient. The claim would be billed listing the PA as the performing provider.

 

Reference

CMS IOM Pub. 100-02 Medicare Benefit Policy Manual, Chapter 15 Covered Medical and other Health Services, Section 60 Services and Supplies Furnished Incident to a Physician’s/NPP’s Professional Service