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2022 – A Transitional Year for Changes to Split/Shared Visit Guidelines

February 23, 2022

Written by: AIHC Blogger

This article provides general guidance related to 2022 and 2023 changes made to split/shared visit guidelines as outlined in the Medicare Claims Processing Manual 100-04, Chapter 12 . Please reference payor and Medicare guidelines for complete information. This article is not intended as coding, consulting or legal advice, but to summarize highlights of the important changes to the documentation, coding and billing of these services.

What Is the Definition of a Split (or Shared) Visit?

According to Medicare, a split (or shared) visit, also referred to as “split/shared” visit, is an evaluation and management (E/M) visit in the facility setting* that is performed in part by both a physician and a nonphysician practitioner (NPP) who are in the same group, in accordance with applicable law and regulations such that the service could be billed by either the physician or NPP (practitioner) if furnished independently by only one of them.

* Facility setting means an institutional setting, such as the hospital, where the hospital is reimbursed for services and supplies furnished incident to a physician or practitioner’s professional services as these items are not at the practitioner’s expense.

Don’t Confuse Office “Incident-to” With Split/Shared Visits

Services performed by non-physician practitioners (NPPs) incident to a physician’s professional services include not only services ordinarily rendered by a physician’s office staff person (e.g., medical services such as taking blood pressures and temperatures, giving injections, and changing dressings) but also services ordinarily performed by the physician such as minor surgery, setting casts or simple fractures, reading x-rays, and other activities that involve evaluation or treatment of a patient’s condition.

Hospital and skilled nursing facility services cannot be billed as "incident-to" at any time.

In order for services of a NPP to be covered as incident-to the services of a physician (and paid at 100% of the fee schedule instead of 85%), the services must meet all of the requirements for coverage specified in Medicare’s policy manual (§§60 through 60.1). For example, the services must be an integral, although incidental, part of the physician’s personal professional services, and they must be performed under the physician’s direct supervision .

The Medicare Benefit Policy Manual, 100-02, Chapter 15 , Section 60 is a great resource to reference as well as your Medicare Administrative Contractor (MAC) for more guidance and tools for compliant incident-to billing.

Payment is made to the practitioner who performs the substantive portion of the visit. So, what does that mean?

“Substantive portion” means more than half of the total time as of January 1, 2023. In 2022, we are in a transitional period.

During the transitional year, from January 1, 2022, through December 31, 2022, (with the exception of critical care visits) the substantive portion can be one of the three key E/M visit components. Remember, 1995 and/or 1997 documentation guidelines apply to E/M other than the physician office visits:

• Medical decision-making (MDM)); or
• More than half of the total time spent by the physician and NPP performing the split (or shared) visit.

In other words, for calendar year 2022, the practitioner who spends more than half of the total time, or performs the history, exam, or MDM can be considered to have performed the substantive portion and can bill for the split (or shared) E/M visit.

When one of the three key components is used as the substantive portion in 2022, the practitioner who bills the visit must perform that component in its entirety in order to bill.

Let’s look at an example: 

• If the history documentation is used as the substantive portion and both practitioners take part of the history, the billing practitioner must perform the level of history required to select the visit level billed.
• When the physical exam is used as the substantive portion and both practitioners examine the patient, the billing practitioner must perform the level of exam required to select the visit level billed.
• When the MDM element is used as the substantive portion, each practitioner could perform certain aspects of MDM, but the billing practitioner must perform all portions or aspects of MDM that are required to select the visit level billed.

Distinct & Qualifying Time

Distinct Time - only distinct time can be counted. When the practitioners jointly meet with or discuss the patient, only the time of one of the practitioners can be counted.

Example: If the NPP first spent 10 minutes with the patient and the physician then spends another 15 minutes, their individual time spent would be summed (10 + 15) to equal a total of 25 minutes.

• The physician would bill for this visit, since they spent more than half of the total time (15 of 25 total minutes).

Now, if, in the same situation, the physician and non-physician practitioner (NPP) met together for five additional minutes ( beyond the 25 minutes ) to discuss the patient’s treatment plan, that overlapping time could only be counted once for purposes of establishing total time and who provided the substantive portion of the visit.

• The total time would be 30 minutes.
• The physician would bill for the visit, since they spent more than half of the total time (20 of 30 total minutes).

Qualifying Time - Drawing on the CPT E/M Guidelines, except for critical care visits, the following list of activities can be counted toward total time for purposes of determining the substantive portion when performed, and whether or not the activities involve direct patient contact:

• Preparing to see the patient (for example, review of tests) ;
• Obtaining and/or reviewing separately obtained history;
• Performing a medically appropriate examination and/or evaluation;
• Counseling and educating the patient/family/caregiver;
• Ordering medications, tests, or procedures.;
• Referring or communicating with other health care professionals ( when not separately reported) ;
• Documenting clinical information in the electronic or other health record;
• Independently interpreting results (not separately reported) and communicating results to the patient/family/caregiver; and
• Care coordination (not separately reported).

Practitioners cannot count time spent on the following:

• The performance of other services that are reported separately;
• Teaching that is general and not limited to discussion that is required for the management of a specific patient.

For critical care visits, starting for services furnished in CY 2022, the substantive portion will be more than half of the total time. A unique listing of qualifying activities for purposes of determining the substantive portion of critical care visits applies as compared to other E/M visits or services:

Prolonged Services for Split/Shared Visits

During the transitional calendar year 2022, when practitioners use a key component as the substantive portion, there will need to be a different approach for hospital outpatient E/M visits than other kinds of E/M visits:

• Outpatient - For shared hospital outpatient visits where practitioners use a key component as the substantive portion, prolonged services can be reported by the practitioner who reports the primary service, when the combined time of both practitioners meets the threshold for reporting prolonged hospital outpatient services (HCPCS code G2212).
• Other - For all other types of E/M visits (except emergency department and critical care visits), prolonged services can be reported by the practitioner who reports the primary service, when the combined time of both practitioners meets the threshold for reporting prolonged E/M services other than office/outpatient E/M visits (60 or more minutes beyond the typical time in the CPT code descriptor of the primary service). Note, emergency department and critical care visits are not reported as prolonged services.

Reporting Prolonged Services for Split (or Shared) Visits

Modifier -FS (Split or Shared E/M Visit) must be reported on claims for split/shared visits, to identify that the service was a split (or shared) visit.

• FS          Split (or shared) evaluation and management visit

Documentation in the medical record must identify the physician and NPP who performed the visit. The individual who performed the substantive portion of the visit (and therefore bills for the visit) must sign and date the medical record.

Critical Care and Medical Record Documentation

Critical care is a time-based service, as demonstrated in the code descriptions below:

What hasn’t changed is when management of a patient located in an intensive care unit does not meet the level of critical care. Those visits are reported using an inpatient hospital care service with CPT Subsequent Hospital Care using a code from CPT code range 99231 - 99233. Remember, you can’t report critical care codes 99291 and 99292 just because the patient is in Intensive Care. Also, remember that both Initial Hospital Care (CPT codes 99221 - 99223) and Subsequent Hospital Care codes are “per diem” services and may be reported only once per day by the same physician or physicians of the same specialty from the same group practice. 

What is the definition of “Critical Care” then?

The American Medical Association (AMA) CPT guidelines indicate that critical care is the direct delivery by a physician(s) or other qualified healthcare professional (QHP) of medical care for a critically ill/injured patient in which there is acute impairment of one or more vital organ systems, such that there is a probability of imminent or life-threatening deterioration of the patient’s condition. It involves high complexity decision-making to treat single or multiple vital organ system failure and/or to prevent further life-threatening deterioration of the patient’s condition.

Critical care requires the full attention of the physician or NPP and therefore, for any given time period spent providing critical care services, the practitioner cannot provide services to any other patient during the same period of time. Critical care time does not have to be continuous. Time can be aggregated, but time must be documented in the medical record.

According to Section 30.6.12.8 of the Medicare Claims Processing Manual, Chapter 12, practitioners must document in the medical record the total time (not necessarily start and stop times) that critical care services are furnished by each reporting practitioner.

• Documentation needs to indicate that the services furnished to the patient, including any concurrent care by the practitioners, are medically reasonable and necessary for the diagnosis and/or treatment of illness and/or injury or to improve the functioning of a malformed body member.

Split/Shared Critical Care

When critical care services are furnished as a split/shared visit, the substantive portion is defined as more than half the cumulative total time in qualifying activities that are included in CPT codes 99291 and 99292.

To bill split/shared critical care services, the billing practitioner first reports CPT code 99291 and, if 75 or more cumulative total minutes are spent providing critical care, the billing practitioner reports one or more units of CPT code 99292.

• Modifier -FS (split or shared E/M visit) must be appended to the critical care CPT code(s) on the claim.       o FS - Split (or shared) evaluation and management visit

The same documentation rules apply for split/shared critical care visits as for other types of split/shared E/M visits. Consistent with all split/shared visits, when two or more practitioners spend time jointly meeting with or discussing the patient as part of a critical care service, the time can be counted only once for purposes of reporting the split/shared critical care visit.

Auditing for Concurrent Critical Care

Concurrent care is when more than one physician renders services that are more extensive than consultative services during a period of time. The reasonable and necessary services of each physician furnishing concurrent care is covered when each plays an active role in the patient’s treatment. In the context of critical care services, a critically ill patient may have more than one medical condition requiring diverse, specialized medical services and requiring more than one practitioner, each having a different specialty , playing an active role in the patient’s treatment. This is reflected through the practitioner’s taxonomy code when the claim is filed.

However, there are guidelines for concurrent care of practitioners in the same group or specialty:

• Physician(s) or NPP(s) in the same specialty and in the same group may provide concurrent follow-up care, such as a critical care visit subsequent to another practitioner’s critical care visit.
• This may be as part of continuous staff coverage or follow-up care to critical care services furnished earlier in the day on the same calendar date. In the situation where a practitioner furnishes the initial critical care service in its entirety and reports CPT code 99291, any additional practitioner(s) in the same specialty and the same group furnishing care concurrently to the same patient on the same date report their time using the code for subsequent time intervals (CPT code 99292).
• CPT code 99291 will not be reported more than once for the same patient on the same date by these practitioners. This policy recognizes that multiple practitioners in the same specialty and the same group can maintain continuity of care by providing follow-up care for the same patient on a single date.
• When one practitioner begins furnishing the initial critical care service, but does not meet the time required to report CPT code 99291, another practitioner in the same specialty and group can continue to deliver critical care to the same patient on the same date.
• The total time spent by the practitioners is aggregated to meet the time requirement to bill CPT code 99291. Once the cumulative required critical care service time is met to report CPT code 99291, CPT code 99292 can only be reported by a practitioner in the same specialty and group when an additional 30 minutes of critical care services have been furnished to the same patient on the same date (74 minutes + 30 minutes = 104 total minutes).

Provide Sufficient Concurrent Care Documentation

To support coverage and payment determinations regarding concurrent care , services must be sufficiently documented to allow a medical reviewer to determine the role each practitioner played in the patient’s care (that is, the condition or conditions for which the practitioner treated the patient). When critical care services are reported the same date as another E/M visit, the medical record documentation must support:

• The other E/M visit was provided prior to the critical care services at a time when the patient did not require critical care; 
• The services were medically necessary; and  
• Services were separate and distinct, with no duplicative elements from the critical care services provided later on that date.

When critical care services are furnished in conjunction with a global procedure, the medical record documentation must support that the critical care was unrelated to the procedure.

Additional Resources

• Medicare Claims Processing Manual 100-04, Chapter 12 - Physicians/Nonphysician Practitioners
• Short Course in Clinical Documentation Improvement – for Physician Services (pro fee filed on 1500 claim). This training is designed for Practitioners, Practice Administrators, Office Nurses, Coders, Professional Auditors and others tasked with the responsibility to improve documentation standards for medical practices.

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• E/M Coding and Billing Res...
• Split-Shared EM Visits

Reporting Split/Shared E/M Visits in 2024

Beginning January 1, 2024, the Centers for Medicare & Medicaid Services (CMS) will implement a new split (or shared) evaluation and management (E/M) billing policy for E/M visits provided in part by a physician and in part by a nonphysician practitioner (NPP). The billing provider for such visits will be the physician or NPP who furnished the “substantive portion” of the visit. CMS defines “substantive portion” to mean more than half of the total time spent by the physician or NPP performing the split/shared visit or the substantive part of the medical decision making (MDM) during the split/shared visit.

A split/shared visit is an E/M visit in a hospital or other facility setting that is performed in part by both a physician and an NPP who are in the same group practice. A split/shared E/M visit may be provided to a new or established patient for an initial or subsequent visit.

No. This new split/shared E/M visit reporting policy applies only to those furnished in a facility setting. In a nonfacility setting, such as a physician’s office, different reporting rules apply when an NPP provides some or all of an E/M visit and the physician bills for the visit. This type of E/M visit is referred to as an "incident-to" service.

Medicare defines an NPP as a nurse practitioner, physician assistant, certified nurse specialist, or certified nurse midwife. All of these practitioners may independently report E/M services if they are legally authorized and qualified to furnish an E/M service in their state. NPPs who care for Medicare patients in a facility must enroll in the Medicare program to bill for the services they provide.

CMS has yet to provide a definition of "same group" at this time, but has indicated that a physician and an NPP must work jointly to furnish all of the work related to the E/M in circumstances when a split/shared visit is appropriately billed. If a physician and NPP are in different groups, the physician and NPP would be expected to bill independently and only for the services each fully furnishes.

CMS has adopted the following Current Procedural Terminology (CPT ® ) guidelines for reporting a split/shared E/M visit:

If the physician or other QHP 1 performs a substantive portion of the encounter, the physician or other QHP may report the service. If code selection is based on total time on the date of the encounter, the service is reported by the professional who spent the majority of the face-to-face or non-face-to-face time performing the service. For the purpose of reporting E/M services within the context of team-based care, performance of a substantive part of the MDM requires that the physician(s) or other QHP(s) made or approved the management plan for the number and complexity of problems addressed at the encounter and takes responsibility for that plan with its inherent risk of complications and/or morbidity or mortality of patient management. By doing so, a physician or other QHP has performed two of the three elements used in the selection of the code level based on MDM. If the amount and/or complexity of data to be reviewed and analyzed is used by the physician or other QHP to determine the reported code level, assessing an independent historian’s narrative and the ordering or review of tests or documents do not have to be personally performed by the physician or other QHP because the relevant items would be considered in formulating the management plan. Independent interpretation of tests and discussion of management plan or test interpretation must be personally performed by the physician or other QHP if these are used to determine the reported code level by the physician or other QHP. 2

CMS relies on the list of activities included in CPT E/M Guidelines that count toward total time for purposes of who reports the split/shared visit and for the level of code selected. Based on these guidelines, physician/NPP time includes the following activities:

• Preparing to see the patient (such as review of tests)
• Obtaining and/or reviewing separately obtained history
• Performing a medically appropriate examination and/or evaluation
• Counseling and educating the patient/family/caregiver
• Ordering medications, tests, or procedures
• Referring and communicating with other health care professionals (when not separately reported)
• Documenting clinical information in the electronic or other health record
• Independently interpreting results (not separately reported) and communicating results to the patient/family/caregiver
• Care coordination (not separately reported)

Physician/NPP time does not include the following activities:

• Performance of other services that are reported separately
• Teaching that is general and not limited to discussion that is required for the management of a specific patient

No. For all split/shared E/M visits, only one of the practitioners must have face-to-face (in-person) contact with the patient, but it does not necessarily have to be the practitioner who performs the substantive portion and bills for the visit. When reporting a split/shared visit using total time, the substantive portion could be provided entirely with or without direct patient contact and will be determined based on the proportion of total time, not whether the time involves direct or in-person patient contact.

Yes. If code selection is based on total time on the date of the encounter, the service is reported by the physician/NPP who spent the majority of time performing the service.

CMS has not yet released specific documentation requirements for reporting a split/shared E/M visit. However, it is best practice that the medical record identify the two practitioners who performed the split/shared visit, the activities each practitioner performed, and the time spent by each practitioner. In addition, the individual who performed the substantive portion—and therefore bills the visit—must sign and date the medical record. CMS has emphasized that, although any member of the medical team may enter information into the medical record, only the reporting provider may review and verify notes made in the record by others for the services the reporting clinician furnishes and bills.

The new split/shared E/M visit guidelines indicate that performance of a substantive part of the MDM requires that the physician or NPP who will bill the visit made or approved the management plan for the number and complexity of problems addressed at the encounter and takes responsibility for that plan with its inherent risk of complications and/or the morbidity or mortality of patient management. By doing so, a physician or NPP has performed two of the three elements used in the selection of the code level based on MDM.

Yes. CMS requires that HCPCS modifier –FS ( Split or shared E/M visit ) be appended to the facility claims for split/shared E/M visits, no matter if the physician or NPP bills for the visit. This modifier does not apply to incident-to office visits.

No. Critical care E/M services (e.g., CPT codes 99291-99292) are reported based solely on time. MDM is not a component of these CPT codes.

Please note that the reporting details above are suggestions only and should not be construed as official coding/billing rules.

1 CPT, in general, refers to NPPs as other qualified healthcare professionals (QHPs). With respect to reporting split/shared services in a facility setting, NPPs and other QHPs are synonymous.

2 2024 CPT Codebook, pg. 6.

All specific references to CPT codes and descriptions are © 2023 American Medical Association. All rights reserved. CPT is a registered trademark of the American Medical Association.

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Evaluation and Management (E&M) Split (or Shared) Visits – 2022 Summary of Changes

The 2022 Final Rule defines split (or shared) visits as evaluation and management (E&M) visits in the facility setting that are performed in part by both the physician and a non-physician practitioner (NPP) who are in the same group, in accordance with applicable laws and regulations. Additionally, split/shared visits are further defined as those that:

• Take place in an institutional setting in which payment for services and supplies furnished incident to a physician or practitioner’s professional services is prohibited by the Centers for Medicare & Medicaid Services (CMS); and
• Are furnished in accordance with applicable laws and regulations, including conditions of coverage and payment, such that an E&M visit could be billed by either the physician or the NPP if it were furnished independently by only one of them in the facility setting (rather than as a split/shared visit.)

CMS has stated that limiting split/shared visits to institutional settings only, for which “incident to” payment is not available, would allow for improved clarity and clearly distinguish the policies applicable to such visits from the policies applicable to services furnished incident to the professional services of a physician. CMS further explained that they did not see a need to allow split/shared visit billing in the office setting, because the “incident to” regulations govern situations in which an NPP works with a physician who bills for the visit.

“Physician practices have been billing for split/shared visits in the office setting for many years now,” said Kathy Pride, Panacea Healthcare Solutions Executive Vice President for Coding and Documentation Services. “Most providers are focusing on patient care and do not necessarily read the billing regulations on a regular basis and may not be aware that the split/shared visit is no longer allowed in the office setting.”

CMS is also now including certain skilled nursing facility/nursing facility E&M visits under this definition, and for critical care, which were previously excluded from split/shared billing.

The practitioner who bills for the split/shared visit should be the practitioner who performs the substantive portion of the visit. The “substantive portion” is defined as “more than half of the total time spent by the physician and NPP performing the split/shared visit.” However, CMS is allowing one transitional year (2022) to include in the definition, noting that “the substantive portion of the visit can also be defined as one of the three key components (history, exam, or medical decision-making/MDM).” It is important to note that starting Jan. 1, 2023, time will be the sole basis for split/shared visits, and the substantive portion will be defined as “more than half of the total time.”

CMS also clarified that when one of the three key aforementioned components is used as the substantive portion in 2022, the practitioner who bills the visit must perform that component in its entirety. CMS has also clarified that only one of the practitioners must have a face-to-face (in-person) contact with the patient, but it does not necessarily have to be the practitioner who performs the substantive portion and bills for the visit. The substantive portion could be entirely with or without direct patient contact, and will be determined by the proportion of total time, not whether the time involves direct or in-person patient contact.

“A lot of the times, the guideline changes are slow to be adopted, due to the fact that the physicians are not getting the information in timely fashion,” Pride added. “Therefore, it is important that the compliance and coding leadership/education teams get the word out to the providers that the rules have changed.”

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• Pay Invoice

New Medicare Rules for Split / Shared Visits: What’s Changing and What To Do

In the 2022 Medicare Physician Fee Schedule Final Rule (Final Rule), the Centers for Medicare & Medicaid Services (CMS) announced new rules for split/shared visits in the facility setting. For 2022, such visits may be billed under the National Provider Identifier (NPI) of the physician or non-physician practitioner (NPP) who either (1) documents the support for the history, exam, or medical decision-making for the visit, or (2) provides more than 50% of the service time. For 2023, split/shared visits must be billed under the NPI of the individual who provides more than 50% of total visit time.   

These new rules could significantly impact Medicare reimbursement for physician practices that use NPPs in facility settings. For evaluation and management (E/M) visits jointly furnished by a physician and NPP in the same group practice in a facility setting (e.g., place of service [POS] 21 inpatient hospital or 22 provider-based clinic), CMS has permitted the visit to be billed under the physician’s NPI. Specifically, CMS’ split/shared visit rule has required that a physician perform only some portion of the E/M visit in order to bill that service under the physician’s NPI. Thus, the practice received full payment for the visit rather than the 85% of the Physician Fee Schedule rate paid for services billed under an NPP’s NPI. 

In the Final Rule, CMS clarified and made several changes to its rules for split/shared visits: 

• The split/shared visit rules do not apply to office visits (place of service 11); instead, these visits may be billed ‘incident to” if the requirements are satisfied (established patient, established plan of care/condition, direct supervision). CMS has signaled that it will be reviewing the incident to rules in future rulemaking.  
• CMS now will permit split/shared visits to be reported for new patients as well as established patients, for initial as well as subsequent visits, for critical care services, for prolonged E/M visits, and for skilled nursing facility/nursing facility E/M visits (other than those required to be performed in their entirety by a physician).
• CMS will require the use of a new modifier (yet to be identified) to identify all claims for split/shared visits.
• Documentation in the medical record must identify the two individuals (physician and NPP) who performed the visit.
• For 2022 only, split/shared visits may be billed under the physician’s NPI if (1) the medical record documentation indicates the physician performed one of the three key components (history, exam, or medical decision-making) in its entirety, or (2) more than half of the total time for the visit was spent by the physician. Otherwise, the visit must be billed under the NPP’s NPI. (For critical care services, only time may be used.)
• Beginning in 2023, only time will be used to determine the substantive portion of the visit.

            Table 26 in the Final Rule summarizes these requirements: 

Many practices now have an NPP perform initial rounds in the hospital, followed by a physician briefly seeing each patient later in the day. These practices now bill these services under the physician’s NPI and thus receive 100% of the Physician Fee Schedule rate. Going forward, however, it is unlikely the time spent by the physician will exceed the NPP’s time. Thus, these services will have to be billed under the NPP’s NPI, and the practice’s reimbursement will be reduced by 15%. 

Compliance tips:

• Only apply these rules to Medicare claims reporting. Monitor other payers for their split/shared visit requirements, which are usually a part of the payer’s incident to policy.
• Review physician and NPP contracts for potential impacts to compensation as the billing for these services will likely shift to the NPP. Work relative value unit (wRVU) capture for these providers will likely be different from what was anticipated during the compensation design.
• Time-based: Select the billing provider based on the predominance (more than 50%) of time spent.
• E/M guidelines-based (2022 only): Select the physician only if history, exam, or MDM are fully documented in support of the code to be reported.

If documentation is lacking from the physician, including time or a full component, report the code under the NPP’s NPI.

• Time-based: Select the level of code based on 1995 or 1997 E/M documentation guidelines. Note that supporting this time requires documentation of counseling and/or coordination of care exceeding 50% of the physician’s unit or floor time focused on the patient. Use of total time is recommended.
• E/M guidelines-based: Use the documentation of both providers per the 1995 or 1997 E/M guidelines key components to select the level of service supported.
• Ensure Medicare enrollment for NPPs is active and accurate.
• Monitor Medicare Administrative Contractor (MAC) guidance on the application of this new policy.
• Use this PYA checklist to evaluate compliance with the new rules:

For related information, view our webinar “Timely, Tough, or Tricky – Physician Comp and FMV Topics | Group Practice Exception Changes and APPs” .

If you require assistance relating to E/M documentation and coding compliance, or with any matter involving compliance, valuation, or strategy and integration, one of our executive contacts would be happy to assist. You may email them below, or call (800) 270-9629. 

Executive Contacts

Thanks for reaching out. You can contact me at 404-266-9876.

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April 16, 2024

CMS’s 2024 Shared or Split Services Policy: Document and Report Them Correctly

In 2024, CPT expanded its definition of split/shared services, CMS updated their requirements.

• CPT expanded its definition of split/shared services in 2024, stating that the substantive portion can be determined by the practitioner who spent more than 50% of the time, or who made or approved the medical decision making.
• CMS will allow the substantive portion to be determined based on the practitioner who spent more than 50% of the time or the practitioner who performs the medical decision making (MDM).  They have removed allowing documenting history or exam in its entirety, since these are not current CPT concepts.
• CMS continues to say that this is a delay until 2025 when only time can be used, but this is the third delay by my count.
• CMS says when the work is shared, “we expect that whoever performs the MDM and subsequently bills the visit would appropriately document the MDM in the medical record to support billing of the visit.”
• Services may include both face-to-face and non-face-to-face activities.
• Services billed using the physician’s NPI are paid at a higher rate than those billed by a non-physician practitioner.
• For Medicare, shared services may only be done in a facility setting; shared services may not be performed in place of service 11 for Medicare patients. CMS notes that there is an incident to benefit for the non-facility setting.
• CPT is silent about location.
• Medicare requires HCPCS modifier FS- Split (or shared) Evaluation and Management service to identify shared services.
• Terminology: CPT uses “other qualified health care professionals” and CMS uses “non-physician practitioners” to describe APRNs and PAs who have E/M in their scope of practice in the E/M section of the CPT book.

CPT Split/Shared Services Guidance 2024

All CPT quotes from p.6 CPT 2024 Professional Ed. AMA, 2024

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E/M services may be billed as shared or split services when they are jointly performed by a physician and another practitioner who has E/M in their scope of practice, i.e., APRNs, PAs.  CPT notes that physicians and qualified  health care professionals (QHPs) often act as teams in caring for patients, and may work together during a single encounter.  The 2024 CPT book continues to allow practitioners to determine the substantive portion by time or MDM. If using time, he practitioner who spent greater than 50% of the time can report the service; time spent with the patient jointly by both practitioners can only be counted once.

If using MDM to determine the substantive portion. CPT says:

“… performance of a substantive part of the MDM requires that the physician(s) or other QHP(s) made or approved the management plan for the number and complexity of problems addressed at the encounter and takes responsibility for that plan with its inherent risk of complications and/or morbidity or mortality of patient management. By doing so, a physician or other QHP has performed two of the three elements used in the selection of the code level based on MDM.”

But, CPT adds a distinction between the three elements. If the number and complexity of problems and risk are used to select the level of service, the encounter can be reported by the practitioner who “takes responsibility for that plan.” If data is one of the three elements it is more complicated.

“If the amount and/or complexity of data to be reviewed and analyzed is used by the physician or other QHP to determine the reported code level, assessing an independent historian’s narrative and the ordering or review of tests or documents do not have to be personally performed by the physician or other QHP, because the relevant items would be considered in formulating the management plan. Independent interpretation of tests and discussion of management plan or test interpretation must be personally performed by the physician or other QHP if these are used to determine the reported code level by the physician or other QHP.”

That is, if data is one of the elements in selecting the level of service and there is an independent interpretation or discussion of management or test results with another health care professional that is being used to select the level of code, those activities must be done by the billing clinician (to support the substantive portion). Side note: This will be difficult to explain to practitioners and audit.

Location and wording

CPT is silent about location, not restricting the use of split/shared services to any location.

CPT is silent about who must document the visit. The wording, “… made or approved the management plan…”  seems to imply that an attestation statement is sufficient.

CMS rules 2024

CMS continues to use the terms “nonfacility” and “noninstutional” to describe place of service where split/shared services are allowed. Specifically in the 2024 Final Rule, they state that in the office, incident to rules apply, not split/shared.  Use CPT place of service codes to determine if the setting is a facility or non-facility.  Office and other outpatient services (99202–99215) reported in place of service 11 office may not be reported as shared services. Office and other outpatient codes in place of service 19 or 22, outpatient hospital, may be reported as shared services.

This is what CMS says about documentation of split/shared services. “Although we continue to believe there can be instances where MDM is not easily attributed to a single physician or NPP when the work is shared, we expect that whoever performs the MDM and subsequently bills the visit would appropriately document the MDM in the medical record to support billing of the visit.” p. 475  of the Final Rule. Link at the end of the article.

“Appropriately document” is not defined by CMS. However, some MACs in 2023 have described what the physician needs to document to support billing the substantive portion. NGS, in their E/M Q&A section says this:

“10) Would you consider a shared/split service if the MD’s documentation was listed as an addendum on the NPP’s note? Answer: Split/shared services in the hospital setting require performance of the medically necessary elements (history, exam, MDM) or cumulative time spent by both the billing physician and NPP. The only way for a physician and NPP to describe his/her own personal contribution to the service is to document an individual note describing the portion of the service performed. Example: “I have seen and examined the pt. with the PA and agreed with  A/P  and physical exam findings (and then a summary of items/data already listed by the PA,” the physician is indicating his/her participation in the physical examination and review of the medical decision making; this would be adequate to support the physician’s participation. In order to bill the service as the “substantive” provider, the physician’s documentation would need to describe the physician’s work as exceeding the NPP’s work in completing the service. In either reviewing the NPP’s history and/or exam findings and in formulating a medical decision, the physician’s performance and documentation would need to exceed the NPP’s efforts and documentation of the split/shared service.”

https://www.ngsmedicare.com/ja/evaluation-and-management?lob=96664&state=97224&rgion=93623&selectedArticleId=330568

If NGS is your MAC, the physician must document their own medical decision making, if MDM is used to select the code level. Check your own MAC.

Whoever is billing for the service, CMS requires that the documentation must identify the two individuals who performed the service and the billing professional signs and dates the record.

CMS Final Rule can be found here:

https://public-inspection.federalregister.gov/2023-24184.pdf

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Issue Alerts

Providers Take Note: CMS Makes Changes to Final Split/Shared Visit Rule for 2024

December 28, 2023

By: Brooke Bennett Aziere and Nancy E. Musick

At long last, the Centers for Medicare and Medicaid Services (“CMS”) has finalized its new split/shared visit rule for physicians and nonphysician practitioners (“NPP”). Importantly, CMS has decided to — once again — revise its definition of what constitutes the “substantive portion” of an evaluation and management (“E/M”) visit. 

As background, a split/shared visit is an E/M visit in the facility setting that is performed in part by both a physician and an NPP who are in the same group practice that either provider could bill for if the physician or NPP performed the entire service independently. A “facility setting” means “an institutional setting in which payment for services and supplies furnished incident to a physician or practitioner’s professional services is prohibited under [Medicare] regulations.” The facility setting includes hospital and skilled nursing facility settings. CMS pays the provider who performs the “substantive” portion of the visit.

Over the years, CMS has changed its definition of “substantive portion” a number of times. In the past, a physician could bill a split/shared service if he/she performed any face-to-face portion of the visit, even if the NPP performed the majority of the work. In 2022 rulemaking, CMS revised the rule to allow a provider to bill for the visit if the provider performed any one of these categories: (1) history; (2) performing a physical exam; (3) medical decision-making; or (4) spending time (more than half of the total time spent by the practitioner who bills the visit). 

Then, CMS announced that the split/shared visit rule would be changing effective Jan. 1, 2023.  CMS indicated that it planned to eliminate all of the service categories (i.e., history, physical exam, and medical decision-making) and move to a time-based definition of what constitutes the substantive portion of a split/shared visit. In other words, only the provider who spent more than half of the total time of the service could bill for the visit. CMS delayed implementation of the new rule, instructing providers to continue using the 2022 rulemaking throughout 2023. Providers anticipated that as of Jan. 1, 2024, CMS would implement the time-based definition of “substantive portion.”

But after a lot of pushback, CMS changed course. Starting Jan. 1, 2024, Medicare will pay for a split/shared E/M visit at the rate of the provider who either (1) spent more than half of the total time spent by the providers performing the visit or (2) performed a substantive part of the medical decision-making. This means that providers will still have the ability to bill for a physician’s service in a split/shared visit if the physician did not spend more than half of the time with a patient, but performed a “substantive part of the medical decision-making,” such as developing the plan of care and assuming the responsibility for the patient. See 88 FR 78818, 78982-78985. CMS made clear that it reached this decision, in part, to align its definition of “substantive portion” of a visit with the Current Procedural Terminology (“CPT”) code definition.

Although CMS has aligned its definition with the CPT code, providers should be mindful of CMS’ documentation requirements. While the CPT code would allow a physician to merely review a NPP’s notes and add his/her signature to show he/she agrees with the NPP, CMS expects that the medical record will contain sufficient documentation to show which provider performed the medical decision-making portion of the visit. This means that a physician’s signature, on its own, is likely not enough to support billing at the physician’s rate for the split/shared visit.

Bottom Line for Providers

Providers should keep in mind that there are three elements of medical decision-making: (1) number and complexity of diagnoses to be addressed; (2) the amount and/or complexity of data to be reviewed; and (3) the risk of complications or morbidity from testing or treatment. With respect to the data element, remember that only the provider who interprets the test may utilize that element for purposes of satisfying the split/shared visit rule.

If providers elect to utilize the time-based option, they will need to carefully track and document in the medical record the time each provider spends with the patient. The key takeaway for providers utilizing the time-based option is that only one provider can take credit for the minutes with a patient when both providers are in the room. For example, if the physician and NPP were in the room at the same time evaluating the patient for 15 minutes, then either the physician or NPP could count the 15 minutes toward the time-based calculation of “substantive portion.” 

Providers should also ensure that medical records contain sufficient information to show who performed the substantive portion of the visit; a physician’s signature is not enough on its own. The provider who bills the split/shared visit is the provider who must sign and date the medical record. Additionally, all split/shared visits must be submitted with the “FS” modifier.

For more information on split/shared visits, refer to the Nov. 16, 2023, rulemaking available at https://www.federalregister.gov/documents/2023/11/16/2023-24184/medicare-and-medicaid-programs-cy-2024-payment-policies-under-the-physician-fee-schedule-and-other .

For More Information

If you have questions or want more information regarding CMS' split/shared visit rule, contact your legal counsel. If you do not have regular counsel for such matters, Foulston Siefkin LLP would welcome the opportunity to work with you to meet your specific business needs. Foulston’s healthcare lawyers maintain a high level of knowledge regarding federal and state regulations affecting the healthcare industry. At the same time, our healthcare practice group's relationship with Foulston’s other practice groups, including the taxation, general business, labor and employment, and commercial litigation groups, enhances our ability to consider the legal ramifications of any situation or strategy. For more information, contact Brooke Bennett Aziere at 316.271.9768 or [email protected] , or Nancy E. Musick at 913.253.2140 or [email protected] . For more information on the firm, please visit our website at www.foulston.com.

Established in 1919, Foulston Siefkin is the largest Kansas-based law firm. With offices in Wichita, Kansas City, and Topeka, Foulston provides a full range of legal services to clients in the areas of administrative & regulatory; antitrust & trade regulation; appellate law; banking & financial services; business & corporate; construction; creditors’ rights & bankruptcy; e-commerce; education & public entity; elder law; employee benefits & ERISA; employment & labor; energy; environmental; ERISA litigation; estate planning & probate; family business enterprise; franchise & distribution; government investigations & white collar defense; governmental liability; government relations & public policy; healthcare; immigration; insurance regulatory; intellectual property; litigation & disputes; long-term care; mediation/dispute resolution; mergers & acquisitions; Native American law; oil, gas & minerals; OSHA; privacy & data security; private equity & venture capital; product liability; professional malpractice; real estate; renewable energy, storage, and transmission; securities & corporate finance; startup/entrepreneurship; supply chain management; tax-exempt organizations; taxation; trade secret & noncompete litigation; and water rights.

Additional Resources

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This update has been prepared by Foulston Siefkin LLP for informational purposes only. It is not a legal opinion; it does not provide legal advice for any purpose; and it neither creates nor constitutes evidence of an attorney-client relationship.

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Defining Split or Shared Visits

Split or shared versus incident-to services, determining who reports a split or shared visit, key takeaways, cpt 2024: revisions to guidelines for split or shared visits.

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American Academy of Pediatrics; CPT 2024: Revisions to Guidelines for Split or Shared Visits. AAP Pediatric Coding Newsletter November 2023; 19 (2): 5–7. 10.1542/pcco_book235_document003

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Current Procedural Terminology ( CPT ® ) 2024 brings new guidelines for split or shared visits, including the combined work of a team of physicians and other qualified health care professionals (QHPs) providing portions of a single evaluation and management (E/M) service.

This article addresses the following:

Defining split or shared visits

Split or shared visits versus incident-to services

Determining who reports a split or shared visit

A definition and instructions for reporting split or shared visits based on time were added to CPT in the 2021 code set revisions. For services provided on and after January 1, 2024, CPT guidelines include instructions for reporting split or shared visits based on performance of a substantive portion of either total time or the level of medical decision-making (MDM).

CPT defines a split or shared visit as an E/M service provided in part by physicians and other QHPs. The concept of split or shared visits applies only to face-to-face and non–face-face services provided in part by different professionals who are practicing in the same exact specialty and same group practice. The work of professionals of different specialties or subspecialties or different group practices is separately reported. Guidelines for split or shared visits are focused on determining which team member reports a split or shared visit.

Appropriately reporting split or shared visits is important for correct payment when a payer’s contractual rates of payment differ for services performed by a physician versus a QHP. For example, a plan may pay for services by a QHP at 85% of the contractual rate for a service when performed by a physician.

The split or shared visit concept is especially important in a hospital setting where a team of physicians and QHPs of the same specialty and same group practice provide hospital inpatient or observation services at different times on the same calendar date. CPT does not limit the use of split or shared billing by site of service. Some payers may apply the split or shared visit guidelines to outpatient E/M visits, while others may apply Medicare’s policy that split or shared guidelines apply only to E/M services provided in a facility setting. In office and other outpatient settings, an incident-to policy may be applied in lieu of policy for a split or shared visit. There are important distinctions between split or shared visits and visits provided under incident- to policy, as shown in the Table .

Comparison of Split or Shared and Incident-to Policies

Abbreviations: CPT , Current Procedural Terminology; ED, emergency department; QHP, qualified health care professional; SNF, skilled nursing facility.

Learn more about incident-to policy in Chapter 7 (“Non-preventive Evaluation and Management Services in Outpatient Settings”) of Coding for Pediatrics 2024 ( www.aap.org/Coding-for-Pediatrics-2024-29th-Edition-Paperback ).

CPT 2024 provides the following guidance when selecting which team member reports a split or shared visit. There are 2 options for determining who reports the service.

Majority of total time: When code selection is based on total time on the date of the encounter, the service is reported by the professional who spent the majority of the face-to-face or non–face-to-face time performing the service.

Substantive part of MDM: When code selection is based on the level of MDM, the professional who provided the substantive part of the MDM for the E/M service reports the service.

Reporting based on total time requires documentation of the total time spent by each professional on the date of service. Time spent jointly by 2 professionals performing a split or shared visit is counted only once (ie, each minute is counted only once in the combined total time of service).

Daily normal newborn care and neonatal intensive or critical care services are not subject to split or shared service guidelines, as code selection for these services is not time-based or based on the level of MDM. Although these services may be provided by a team of health care professionals throughout a day, the services are reported by the physician or QHP who is directing the patient’s care.

Reporting based on the substantive part of the MDM for the visit requires that the physician or QHP has performed 2 of 3 elements of MDM (number and complexity of problems addressed [problems addressed], amount and/or complexity of data to be reviewed and analyzed [data], and/or risk of complications and/or morbidity or mortality of patient management [risk]) as required for the level of service reported. Guidelines provide instruction for determining which professional performed the substantive portion of MDM.

Problems addressed and risk: The professional who made or approved the management plan for the problem(s) addressed and who takes responsibility for the inherent risks of the management plan is considered to have performed the substantive portion of the service.

Consider the documented history from an independent historian and documented tests ordered or results/documents reviewed to have been used by the professional in formulating the management plan. The professional reporting the service does not have to personally perform these activities.

An independent interpretation of a test or discussion of management with an external physician, QHP, or appropriate source is used in selecting the amount and/or complexity of data to be reviewed and analyzed when personally performed by the individual reporting the service .

Some payers may require that modifier FS (split or shared E/M visit) be appended to the E/M code when reporting a split or shared visit.

Dr Andrews is contacted by an emergency department (ED) physician at 8:00 am with a request to admit a patient to inpatient status for an acute illness with systemic symptoms and a high risk of morbidity without treatment. Dr Andrews reviews the patient’s medical record via remote access and agrees to order admission. At 8:30 am, a nurse practitioner in Dr Andrews’s group practice and exact same specialty provides an initial E/M service and documents 40 minutes of service. Later that day, Dr Andrews reassesses the patient after reviewing the patient’s hospital record and independently reviewing radiographic images from earlier that day. Dr Andrews spends 30 minutes discussing the patient’s diagnosis and the plan of care with the patient’s parents before writing orders and documenting an updated assessment and plan. Dr Andrews’ documented total time of service on this date is 50 minutes. Dr Andrews selects the codes for the split or shared service based on the combined total time of 90 minutes spent on this date. Codes reported are 99223 FS (first 75 minutes) and 99418 FS (1 unit of prolonged service for the final 15 minutes of service).

Dr Andrews is contacted by an ED physician at 8:00 am with a request to admit a patient to inpatient status for an acute illness with systemic symptoms and a high risk of morbidity without treatment. Dr Andrews reviews the patient’s medical record remotely and agrees to order an admission. At 8:30 am, a nurse practitioner in Dr Andrews’s group practice and exact same specialty provides an initial E/M service documenting history from the patient’s parents, reviewing results of 4 tests ordered by an ED physician prior to admission, and communicating with a subspecialist for advice on management. Later that day, Dr Andrews sees the patient briefly, reviews the nurse practitioner’s documentation, independently reviews radiographic images, and documents an impression before revising the assessment and plan for managing the patient’s condition. Total time of service is not documented.

This E/M service must be reported based on MDM because total time is not documented. The elements of MDM for which Dr Andrews may take credit are addressing a problem that is an acute illness with systemic symptoms and has a high risk of morbidity without treatment, reviewing 4 test results and independent review of radiographic images, and making a decision about hospitalization. Dr Andrews may not take credit for the discussion of management between the nurse practitioner and subspecialist because this element must be personally performed. Dr Andrews reports initial hospital inpatient or observation care with high-level MDM, 99223 FS .

Learn more about reporting split or shared visits and other hospital inpatient and observation services in chapters 6 (“Evaluation and Management Documentation Guidelines”) and 17 (“Noncritical Hospital Evaluation and Management Services”) in Coding for Pediatrics 2024 ( www.aap.org/Coding-for-Pediatrics-2024-29th-Edition-Paperback ).

This article provided a review of split or shared visits and the 2024 CPT guidelines for reporting these services. Individual payers may adopt payment policies that differ from CPT , so it is best to review the policies of payers commonly billed by your practice.

When reporting split or shared services based on CPT guidelines, remember these points.

The concept of split or shared visits applies only to face-to-face and non–face-face services provided in part by a physician and a QHP when each professional is practicing in the same exact specialty and same group practice.

Some payers may apply Medicare’s policy that split or shared guidelines apply only to inpatient or observation care provided in a facility setting. Services in office settings may be subject to incident-to policy in lieu of split or shared guidelines.

Reporting is based on which professional spent the majority of total time or performed the substantive part of the MDM for the visit (ie, performed 2 of 3 elements of MDM).

The professional reporting the service does not have to personally perform documented history from an independent historian and/or documented tests ordered or results/documents reviewed to include these in determining the amount and/or complexity of data to be reviewed and analyzed.

Independent interpretation of a test or discussion of management with an external physician, QHP, or appropriate source is used in selecting the amount and/or complexity of data to be reviewed and analyzed when personally performed by the individual reporting the service.

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Distinct Time versus Total Time for the 2022 Split (or Shared) Visit

• By Erica Remer, MD, FACEP, CCDS, ACPA-C
• January 31, 2022

Confusion continues to obfuscate the intent of this new regulation, creating uncertainty for coding, billing and compliance.

There is a hierarchy in coding: the Official Coding and Reporting Guidelines and the American Health Association (AHA) Coding Clinics give recommendations on how to derive the correct code, but the ultimate, definitive source is the Tabular List.

Final rules are often lengthy, which I will attest to as someone who has slogged through their thousands of pages; however, David Glaser, an esteemed lawyer on Monitor Mondays, recently explained to me that the actual regulation is short. What you read in the Federal Register is the Preamble, the commentary, the exposition, similar to the Official Guidelines.

David and I have been having a lively discussion about the new rule regarding split/shared visits. Such a service is not provided in an office setting. This is a medically necessary visit provided in part by a physician and in part by a nonphysician practitioner (NPP, e.g., physician assistant/associate, nurse practitioner, etc.).

If an evaluation and management (E&M) service is provided as a split/shared visit, it is either billed at 100 percent for the physician or 85 percent of the physician fee schedule rate, if billed under the NPP. The 2022 Final Rule regarding the Physician Fee Schedule (42 CFR 415.140) has fundamentally changed how to determine who bills for split/shared visits.

Historically, a split/shared visit was awarded to the physician if he or she handled the “substantive portion” of the visit, the definition of which was not clearly established. Often, both parties contributed to each element of the visit components, but if the physician had a face-to-face encounter and documented their substantive contribution to the total service, they could claim the visit. The concern was that perhaps some physicians were not providing sufficient contribution to the service to be entitled to bill it at the full 100 percent.

The 2022 Final Rule has made two very significant changes. One is the requirement of performing a component in its totality, and the other is transitioning to a time-based service.

2022 is being considered a transition year, when either the substantive portion of one of the key components (i.e., history, physical examination, or medical decision-making) may be performed in its entirety, or the billing provider must spend more than half the qualifying time performing the permissible elements of the service (e.g., preparation to see the patient, reviewing results of tests or consultative reports, obtaining or reviewing the history, performing a medically appropriate physical examination, counseling the patient and family, or ordering medications, tests, or procedures; as well as creating documentation). In 2023, time will be the only determinant of split/shared visits.

The regulation itself defines a “substantive portion” as “more than half of the total time spent by the physician and the nonphysician practitioner.” The Federal Register explanation muddies the water in the section regarding “distinct time.” First, it says that “the distinct time of service spent by each physician or NPP furnishing a split (or shared) visit would be summed to determine total time, and who provided the substantive portion (and, therefore, bills for the visit).” In the next breath, it says that “this would be consistent with the CPT E&M Guidelines stating that, for split (or shared) visits, when two or more individuals jointly meet with or discuss the patient, only the time of one individual should be counted.”

I’m not sure that this is consistent.

Does the total time include one portion of overlapping time, or two? This was relevant in critical care time, where historically only one provider could claim a given moment in time. For instance, if a hospitalist and an intensivist were both at a patient’s bedside, only one of them could claim critical care time. Put aside the fact that this has been changed, too, in the 2022 Final Rule.

My reading and that of many of the knowledgeable folks whom I have consulted is that for the conjoint time, only the physician or the NPP can be credited with that time: one or the other. David disagrees, and posits that the regulation says you would count the time twice for “total time.” I can see his point from the verbiage. Unfortunately, their example is not enlightening.

Here is the question to ask:

Say the physician and NPP see the patient together for 15 minutes. The physician spends 10 more minutes doing activities that would count towards qualifying time. The NPP spends 12 minutes checking labs, making calls, and documenting. Is the calculation:

• 15 doctor + 15 NPP + 10 doctor +12 NPP = 52 total minutes, and the NPP has 27/52 minutes (> 50 percent), so they bill under the NPP; or
• 15 doctor + overlapping NPP time is nullified + 10 doctor + 12 NPP = 37 minutes of distinct time, and with the physician claiming the 15 minutes of overlapping time, 25/37 minutes (>50 percent), bill under the doctor?

What would happen if the physician and the NPP have exactly the same amount of time, because the Rule says, “more than half”? Which runner does the tie go to?

The reality of taking care of patients is that a lot of the specified qualifying time spent is what we used to refer to as “scut work.” There is no glory in tracking down lab results, entering orders, or filling out paperwork. My prediction is that post-COVID, there are going to be many adjustments needing to be made to account for a workforce shortage. Shoehorning split/shared visits into only allowing for NPPs to bill may adversely impact patient care, and will certainly affect practices’ bottom lines.

I think the Centers for Medicare & Medicaid Services (CMS) was really trying to avoid paying physicians who peep their heads in for a hot second and then bill at 100 percent, and I support that. In order to perform a split/shared visit, the physician must be value-added. I used to do my own history and medically appropriate physical examination of every patient seen on my shift who was being attributed to me. I would always discuss the medical decision-making with my NPP, and we did what I approved. Approximately 25 percent of the time, I changed the plan according to my experience and knowledge base, and my alteration was important for the patient’s care. I cannot swear that I spent more than 50 percent of the shared time with the patient (E&M services in the ED were not time-based), but I still believe I was rightly entitled to bill under me. I was directly responsible for the patient’s care and outcome.

I believe a critical piece of this puzzle will be a compliant attestation (in addition to affixing the correct modifier, indicating that this is a split/shared visit). It will need to say some variation of:

This was a split/shared visit. I attest that I spent [X] number of minutes out of a total [Y] number of minutes engaging in activities such as, but not limited to (when not separately reported): preparation, obtaining history, performing a medically appropriate physical exam, counseling and education, ordering appropriate medications/treatment/testing, referring and communicating with consultants, independently interpreting and discussing results of tests, determining a plan of action, performing care coordination, and creating documentation.

A best practice may be allowing for indicating which of the activities one is claiming, likely by an electronic solution.

From a physician’s perspective, the NPP is allowing the attending to see more patients, and to take excellent care of all of them. You can be sure that if there is a malpractice action, the lawyers are not going to exclude the attending physician if the billing was done under the NPP’s UPIN.

As the physician, I am the captain of the ship, and the buck stops here. Its seems like I should be entitled to that buck if the NPP and I have overlapping time.

Programming Note: Listen to Dr. Erica Remer as she cohosts Talk Ten Tuesdays today with  Chuck Buck at 10 Eastern.

• TAGS: Coding , Compliance , Featured Article

Erica Remer, MD, FACEP, CCDS, ACPA-C

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Dr. Ronald Hirsch presents an essential “A to Z” review of Observation, including proper use for Medicare, Medicare Advantage, and commercial payers. He addresses the correct use of Observation in medical patients and surgical patients, and how to deal with the billing of unnecessary Observation services, professional fee billing, and more.

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Explore the top-10 federal audit targets for 2024 in our webcast, “Top-10 Compliance Risk Areas for Hospitals & Physicians in 2024: Get Ahead of Federal Audit Targets,” featuring Certified Compliance Officer Michael G. Calahan, PA, MBA. Gain insights and best practices to proactively address risks, enhance compliance, and ensure financial well-being for your healthcare facility or practice. Join us for a comprehensive guide to successfully navigating the federal audit landscape.

Mastering Healthcare Refunds: Navigating Compliance with Confidence

Join healthcare attorney David Glaser, as he debunks refund myths, clarifies compliance essentials, and empowers healthcare professionals to safeguard facility finances. Uncover the secrets behind when to refund and why it matters. Don’t miss this crucial insight into strategic refund management.

2024 SDoH Update: Navigating Coding and Screening Assessment

Happy world health day our exclusive webcast is just $99 for a limited time use code worldhealth24 at checkout before april 12th to claim this discount..

Dive deep into the world of Social Determinants of Health (SDoH) coding with our comprehensive webcast. Explore the latest OPPS codes for 2024, understand SDoH assessments, and discover effective strategies for integrating coding seamlessly into healthcare practices. Gain invaluable insights and practical knowledge to navigate the complexities of SDoH coding confidently. Join us to unlock the potential of coding in promoting holistic patient care.

2024 ICD-10-CM/PCS Coding Clinic Update Webcast Series

HIM coding expert, Kay Piper, RHIA, CDIP, CCS, reviews the guidance and updates coders and CDIs on important information in each of the AHA’s 2024 ICD-10-CM/PCS Quarterly Coding Clinics in easy-to-access on-demand webcasts, available shortly after each official publication.

2024 ICD-10-CM/PCS Coding Clinic Update: Fourth Quarter

Kay Piper reviews the guidance and updates coders and CDISs on important information in the AHA’s fourth quarter 2024 ICD-10-CM/PCS Quarterly Coding Clinic in an easy to access on-demand webcast.

2024 ICD-10-CM/PCS Coding Clinic Update: Third Quarter

Kay Piper reviews the guidance and updates coders on information in the AHA’s third quarter 2024 ICD-10-CM/PCS Coding Clinic in an easy to access on-demand webcast.

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Happy World Health Day! Our exclusive webcast, ‘2024 SDoH Update: Navigating Coding and Screening Assessment,’  is just $99 for a limited time! Use code WorldHealth24 at checkout.