Getting credentialed with insurance networks can be lengthy and very frustrating. Providers often have to wait weeks and sometimes months to be able to bill the payers while using their own name. Meanwhile patients keep coming in and the revenue clock is still ticking.
So what happens when you are ready to treat patients but haven’t gotten credentialed yet? Should you wait until the process is complete or is there a compliant way to bill and get paid during that time?
This guide gives you the basics of how to bill as a non-credentialed provider without jeopardizing compliance, while avoiding common mistakes that could cost you time, money, and the future of your payer relationships.
At A2Z Billings, we’ve helped healthcare providers for over a decade keep their billing compliant and streamline cash flow during this tricky credentialing period.
What Does “Non-Credentialed” Mean?
A non-credentialed provider is someone who hasn’t yet been approved by an insurance payer (like Medicare, Medicaid, or commercial plans) to bill for services under their own name or NPI.
This situation typically happens when:
- You’ve recently joined a new practice.
- You’re a new graduate starting out.
- You’ve switched from one payer network to another.
- You’re waiting for credentialing paperwork to process.
During this period, you can still see patients, but billing them directly — or billing insurance incorrectly — can get you into compliance trouble fast.
The Problem: Cash Flow Freeze During Credentialing
The credentialing process can take 60 to 120 days or longer depending on the payer. That’s months of work without guaranteed reimbursement if you’re not billing correctly.
Some providers try to:
- Hold all claims until credentialing is complete (causing major cash flow gaps), or
- Submit claims under their name prematurely (risking denials or fraud flags).
Both options are bad for business. The goal is to keep seeing patients and bill compliantly while your credentialing application is pending.
The Solution: How to Bill During Credentialing (Compliantly)
There are several approved billing pathways for non-credentialed providers — depending on your setup, payer, and state rules.
Let’s break that into a separate category:
1. Incident-To Billing (For Supervising Providers)
Best Utilized by: Physicians, NPs or PAs being credentialed under a supervising provider.
Incident-To services are billed under the supervising physicians NPI while the physician is waiting on your credentialing.
Requirements:
- The supervising provider must be on-site during the service.
- The supervising provider must be involved in the patient’s care plan.
- Documentation must clearly show their oversight.
Benefit: You can start generating revenue immediately while staying compliant.
Caution: Medicare and most payers audit these claims carefully — documentation must be airtight.
2. Substitute Billing
Best for: Temporary coverage or provider transitions.
If a credentialed provider is temporarily unavailable (e.g., on leave), a non-credentialed provider can work as a substitute, billing under the credentialed provider’s NPI for up to 60 continuous days.
Requirements:
- Must use modifier Q6 when billing.
- The credentialed provider must be returning.
- Proper documentation of substitution is mandatory.
Benefit: Seamless patient care continuity without reimbursement delays.
3. Retroactive Billing After Credentialing
Some payers allow retroactive effective dates, meaning once you’re approved, your credentialing can backdate to the application submission date.
Requirements:
- You must have submitted your credentialing application before seeing patients.
- Keep thorough records and dates of service.
Benefit: You can hold claims temporarily and submit them retroactively once approved — avoiding denials.
Pro Tip: Always confirm retroactive policy terms directly with each payer before starting this approach.
4. Out-of-Network (OON) Billing
If you’re not yet in-network, you can still bill out-of-network. Patients will often have higher out-of-pocket costs, but this allows you to keep billing ethically.
Requirements:
- Patients must sign an acknowledgment of OON status.
- Clearly disclose estimated costs.
Benefit: Keeps your revenue moving and builds patient trust through transparency.
5. Cash-Pay Model During Credentialing
For short credentialing gaps or new practices, consider a temporary cash-pay model.
Requirements:
- Post clear pricing.
- Offer itemized receipts (patients can self-submit claims).
Benefit: Immediate cash flow, no payer restrictions.
Drawback: May not suit all patient demographics.
Avoid These Common Compliance Mistakes
Even experienced providers slip up during the credentialing gap. Here are key pitfalls to avoid:
Billing under someone else’s NPI without supervision — a compliance red flag.
Changing NPIs after claim submission — leads to rejections and audits.
Skipping documentation of supervision — leaves no proof for “incident-to” claims.
Failing to verify payer-specific rules — every payer handles credentialing differently.
Remember: Staying compliant is not optional — it protects your reputation, license, and revenue.
How a Professional Billing Partner Helps
Credentialing and billing are two different beasts — and both can eat up your time. A professional billing team ensures you:
- Bill under the right NPI every time.
- Track claim timelines and payer updates.
- Submit retroactive claims properly once you have been credentialed.
- Be 100% compliant with Medicare, Medicaid, and commercial plans.
You focus on care; we handle the compliance maze.
Real Results: What Providers Experience When They Get It Right
When providers handle non-credentialed billing correctly, here’s what happens:
Zero cash-flow gaps – patient visits stay consistent, and revenue keeps moving.
Fewer denials – claims are clean and compliant from day one.
Faster reimbursements – no resubmission delays after approval.
Peace of mind – focus on your patients, not on claim errors.
That’s the real win — confident billing, even before full credentialing.
Action Plan: Step-by-Step Checklist for Non-Credentialed Billing
Here’s a quick implementation guide to keep your practice compliant and cash-positive:
- Confirm credentialing submission date.
- Check payer policies for retroactive billing or incident-to allowances.
- Choose your billing pathway:
- Incident-to
- Retroactive
- ONN
- Cash-pay
- Document everything (supervision, visit notes, service details).
- Communicate with patients about billing status if applicable.
- Work with a billing expert to manage submissions and tracking.
Credentialing delays shouldn’t mean lost revenue or compliance risks. With the right strategy, non-credentialed providers can treat patients, bill correctly, and stay audit-ready throughout the process.
At A2Z Billings, our experts make this transition seamless — managing credentialing, billing, and compliance under one roof. If you’re ready to focus on patient care while we handle the billing maze, reach out today and keep your cash flow uninterrupted.
FAQs
- Can a non-credentialed provider see patients?
Yes, they can — as long as billing and supervision follow payer compliance rules such as “incident-to” guidelines.
- Can you bill insurance as a non-credentialed provider?
You can bill under a supervising provider’s NPI or hold claims for retroactive submission once credentialing is approved.