In this issue of AJHP, Maldonado et al.1 bring to the fore important information on billing the Centers for Medicare and Medicaid Services (CMS) for patient care services provided by pharmacists. Based on my experience in advising numerous clinicians and administrators on creating financially sustainable clinical pharmacist services, I offer the following comments as additional background for and guidance to readers. The authors describe multiple methods for outpatient billing, including incident-to billing and facility or technical fee billing. (The terms facility fee and technical fee are often used interchangeably.) Readers should note that different CMS regulations apply to pharmacist incident-to billing in a physician-based outpatient clinic2 versus incident-to billing in a hospital-based outpatient clinic.3,4 In a physician-based clinic, only one bill is submitted for the provider’s professional fee, which includes a technical fee for overhead costs. However, in a hospital-based clinic, the professional fee and technical fee are submitted on two bills. Because hospitals have large variability in overhead costs, they are permitted to bill separately for these expenses. Hospital-based clinics are allowed to include the expense of a clinical pharmacist within the facility fee as a component of the clinic’s overhead expense.