Have you received a denial from a payer with these words?  "This service was denied as incidental to another service."  Notice that the payer does not say that the service was bundled into another service.  The explanation of benefits from the commercial payer uses the word incidental.

Why?

Because the payer is not using the National Correct Coding Initiative (NCCI) edits, developed by Medicare, and a standard in the industry.  The payer is using a set of edits developed by them or their software company.  More often that not, if you see the word incidental in place of bundled, the NCCI edits were not used.

Your response:  appeal, contact the medical director, calculate the revenue lost/year from these edits, consider dropping the payer, contact the American Medical Association.