Exhibit 3:

Characteristics of direct versus indirect billing practices, Medicare fee-for-service beneficiaries, 2018

	Direct billing practices	Direct and indirect billing practices	Indirect billing practices
Number of practices	7,270	6,107	39,094
Practice type (no.)
Primary care	3,145	2,232	19,806
Specialty	2,507	2,204	17,487
Multispecialty	1,618	1,671	1,801
Number of doctors (mean)	12.3	19.4	2.6
Number of NPs and PAs (mean)	12.2	18.8	4.0
Percentage of rural patients (mean)	33.7	28.3	21.0

SOURCE Authors’ analysis of data from 20 percent random sample of Medicare fee-for-service beneficiaries with Part D coverage for 2010–18. NOTES Only practices with at least one physician and one NP or PA in 2018 were included. We categorized practices with at least one physician and one NP or PA in 2018 as indirect, direct and indirect, or indirect billing practices. Indirect billing practices were defined as practices with more than 80 percent NP and PA visits billed as “incident to.” Direct billing practices were defined as practices with more than 80 percent of NP and PA visits billed directly. The remaining practices were categorized as direct and indirect billing practices. Unadjusted comparisons for practice type, number of doctors, number of NPs and PAs, and percentage of rural patients are significant (p < 0.001).