How to See Patients When the Physician Isn’t Credentialed Yet (2025 Guide)
When a new physician joins a practice, there’s often a gap between their start date and the completion of insurance credentialing. During this time, many practices wonder: Can the physician still see patients? Can we get reimbursed? Are there legal risks?
This guide breaks down everything you need to know about how to legally and ethically see patients when a physician’s credentialing is still pending—including Medicare rules, payer-specific options, billing strategies, patient communication tips, and credentialing best practices.
📌 What Is Credentialing and Why It Matters
Credentialing is the process of verifying a healthcare provider’s qualifications—such as education, licenses, board certifications, work history, and professional references—so that insurance companies can approve them for reimbursement.
Without credentialing:
- You cannot bill insurance under the new provider’s NPI.
- Services rendered by the provider will be denied or unpaid.
- Compliance risks can arise if billed improperly.
Credentialing typically takes 60–120 days, depending on the payer.
⚠️ The Challenge: Delayed Start = Lost Revenue
Imagine hiring a highly skilled provider—but they can’t bill insurance for 3 months. Every week they’re unable to see insured patients costs your practice thousands of dollars.
So what can you do legally while you wait?
Let’s explore your best options below.
✅ Legal Ways to See Patients Before Credentialing Is Complete
1. Incident-To Billing (Medicare Patients Only)
This is a legal Medicare provision allowing non-credentialed providers (like new doctors, NPs, or PAs) to bill under a supervising physician’s NPI.
Requirements:
- The supervising physician must be physically present in the office during patient visits.
- The physician must initiate the patient’s care plan and remain involved.
- The services must be part of ongoing treatment, not new conditions.
Benefits:
- You can receive full Medicare reimbursement.
- Maintains care continuity while waiting on approval.
Risks if misused: If any of the strict conditions aren’t met, billing can be seen as fraudulent.
2. Locum Tenens (Temporary Substitute Billing)
This Medicare-only option allows a new physician to temporarily fill in for a credentialed provider and bill under their NPI for up to 60 days.
Best for:
- Covering vacations, illness, or a departed physician.
- Not ideal for permanent new hires.
Limitations:
- Can’t be used beyond 60 days.
- Strict documentation is required.
- Only applies to Medicare, not commercial payers.
3. Cash Pay (Self-Pay) Patients
You can legally see patients and charge out-of-pocket fees until credentialing is complete.
Important rules:
- Patients must sign informed consent acknowledging no insurance billing.
- Provide a Good Faith Estimate as per the No Surprises Act.
- You may provide a superbill for the patient to seek reimbursement from their insurer.
Pros:
- Immediate revenue with no insurance delay.
- Ideal for concierge or DPC-style care.
Cons:
- Not all patients will agree to self-pay.
- You risk losing potential long-term patients.
4. Billing Under the Group NPI (Check Payer Policies)
Some commercial payers allow billing under the group’s NPI if the provider’s application is in process and retroactive billing is allowed.
Key steps:
- Confirm each payer’s policy in writing.
- Document the date of credentialing submission.
- Keep a detailed paper trail in case of audits.
Warning: Never assume a payer allows retroactive billing. Some require an effective date confirmation before any services are reimbursable.
💡 Other Strategies to Consider
Shadowing or Training Period
Have the new provider shadow an existing physician while waiting on approval. They can:
- Take notes
- Participate in discussions
- Observe procedures
They’re not billing but gaining valuable hands-on experience.
Pre-Credentialing Planning (Best Practice)
Always start the credentialing process 90–120 days before the provider’s start date.
Tips:
- Use credentialing software or a credentialing specialist.
- Keep CAQH profiles current.
- Apply with multiple payers simultaneously.
🧾 Communicating With Patients Transparently
Transparency avoids confusion, billing surprises, and complaints.
What to tell patients:
- “Dr. Smith is in the process of joining your insurance plan.”
- “We’ll file claims as soon as credentialing is complete.”
- “You may choose to self-pay and request reimbursement.”
Use written notices or consent forms to protect your practice.
🚫 Common Mistakes to Avoid
❌ Billing under another provider’s NPI without authorization
❌ Backdating claims once credentialing is approved
❌ Assuming commercial payers follow Medicare rules
❌ Not documenting the supervising physician’s involvement (incident-to)
❌ Forgetting to re-verify NPI approvals before billing
📈 Bottom Line: Yes, You Can See Patients—If You Do It Right
While you can’t bill under a new provider’s NPI until credentialing is complete, you do have options:
- Use incident-to billing for Medicare
- Consider locum tenens for short-term substitution
- Accept cash-pay patients temporarily
- Get payer approval to bill under the group NPI
The key is to understand each payer’s policy, avoid billing fraud, and communicate clearly with both patients and staff.
Jane Smith – Medical Billing Specialist
With over 38 years of experience, Jane Smith helps healthcare providers manage billing, recover payments, and reduce claim denials. She specializes in insurance claims, provider credentialing, and revenue management, ensuring smooth financial operations so doctors can focus on patient care.
