Accurately capturing provider roles in clinical documentation is a unique challenge for medical groups. Documentation drives how payer rules are applied, how time is attributed across clinicians, and how compensation and productivity credit are distributed. The distinctions among billing provider, service provider, co-signer, and preceptor/teaching physician are the basis for revenue integrity, fair workload attribution, and consistent expectations across care teams.

Consider a common encounter: an advanced practice provider (APP) leads most of a patient visit, the physician contributes a substantive portion of counseling and decision-making, and a resident or student participates while learning under supervision. Each participant may play a legitimate role in the care delivered, but payer rules and teaching-physician requirements determine whose NPI is billed, what time (if any) may be counted, and what attestation language is needed.

New for 2026: document how “direct supervision” is met

Starting Jan. 1, 2026, CMS permanently allows direct supervision to be furnished via real-time audio-video (not audio-only) for many services that require direct supervision, with key exceptions (notably certain services with a 10- or 90-day global surgery indicator). This matters directly for incident-to models and any workflow that relies on direct supervision — your documentation and EHR prompts should capture whether supervision was in-suite or audio-video virtual and that the supervising practitioner was immediately available.¹