While The CMC Group is primarily focused on the physician side of reimbursement and compliance we have recently been spending a lot of our consulting time working on the facility side and one of the items continuing to surface are split/shared visits. What are they? Who can bill them? What type of documentation is required to support them?
A split/shared visit is defined as a medically necessary patient encounter in which the physician and a qualified NPP each personally perform a substantive portion of an E&M visit (all or some portion of the history, exam or medical decision making key components of an E&M) face to face with the same patient on the same date of service.
The physician or qualified NPP who performed the E&M visit must personally document the service in the medical record, and the documentation should support the specific level of E&M visit to each individual patient.
Keep in mind that under CMS rules, in a department of a hospital, a physician must see the patient face to face in order to bill under the physician's number.
Office/Clinic Setting
In the office/clinic setting when the physician performs the E/M service the service must be reported using the physician's UPIN/PIN. When an E/M service is a shared/split encounter between a physician and a non-physician practitioner (NP, PA, CNS, CNM), the service is considered to have been performed "incident to" if the requirements for "incident to" are met and the patient is an established patient. If "incident to" requirements are not met for the shared/split E/M service, the service must be billed under the NPP's UPIN/PIN, and payment will be made at the appropriate physician fee schedule payment.
Hospital Inpatient/ Outpatient/ Emergency Department Setting
When a hospital inpatient/outpatient or emergency department E/M is shared between a physician and an NPP from the same group practice and the physician provides any face-to-face portion of the E/M encounter with the patient, the service may be billed under either the physician or the NPP's UPIN/PIN number. However, if there was no face-to-face encounter between the patient and the physician (e.g., even if the physician participated in the service by only reviewing the patient's medical record) then the service may only be billed under the NPP's IPIN/PIN. Payment will be made at the appropriate physician fee schedule rate based on the UPIN/PIN entered on the claim.
Examples of Shared Visits
1. If the NPP sees a hospital inpatient in the morning and the physician follows with a later face-to-face visit with the patient on the same day, the physician or the NPP may report the service.
2. In an office setting the NPP performs a portion of an E/M encounter and the physician completes the E/M service. If the "incident to" requirements are NOT met, the service must be reported using the NPP's UPIN/PIN
*A consultation may not be performed as a split/shared visit.
By: Sean M. Weiss, CPC, CPC-P, CCA-P, CCP-P, CMC
Sr. Partner/ Principal
The CMC Group
Sean M. Weiss is a Senior Partner and Principal with The CMC Group based in Atlanta, Georgia providing a full array of medical office and facility consulting and legal services as well as a full line of coding and compliance tools from AMA, Ingenix, MAG, PMIC and The CMC Group. For more information on The CMC Group or Sean M. Weiss visit them online at www.thecmcgroup.net or at 888-262-8354.
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