Excite Health Partners

SPLIT/SHARED SERVICES: THE IMPORTANCE OF PROPER DOCUMENTATION

SPLIT/SHARED SERVICES: THE IMPORTANCE OF PROPER DOCUMENTATION

When an E/M service is performed in the hospital inpatient (POS 21), hospital outpatient (POS 19, 22), or emergency department (POS 23) and is shared between a physician and non-physician practitioner (NPP) from the same group practice, the service may be billed as a split/shared E/M service.

The CMS definition of split/shared visits can be found in the CMS Internet Only Manual (IOM): Medicare Claims Processing Manual Publication 100-04, Chapter 12, Section 30.6.1 Split/Shared E/M Visit: 

“A split/shared E/M visit is defined by Medicare Part B payment policy as a medically necessary encounter with a patient where the physician and a qualified NPP each personally perform a substantive portion of an E/M visit face-to-face with the same patient on the same date of service.  A substantive portion of an E/M visit involves all or some portion of the history, exam, or medical decision-making key components of an E/M service.  The physician and the qualified NPP must be in the same group practice or be employed by the same employer.”

The following documentation requirements must be met in order to report the service as split/shared:

• Both the physician and the NPP must provide a face to face encounter with the patient.
• Each clinician must document a note in the medical record. Typically, the NPP note is more extensive, but that is not a requirement.
• Physician must document at least one element of the history, exam, and/or medical decision- making component of the E/M service.  It is not sufficient for the physician to simply document “seen and agree” or simply countersign the non-physician practitioner (NPP) documentation. 
• Physician must legibly sign the documentation.
• Physician and the NPP must be actively involved in the Medicare Program and both have a valid provider number for reporting purposes.

The level of E/M service selected to report is based on both the physician and NPP documentation. 

If any of the above elements are lacking, then the service will be reported using the NPP’s NPI.  This will result in a reduction in payment for the E/M service as NPPs receive 85% of the fee schedule rate, whereas reporting using a physician’s NPI number will receive 100% of the fee schedule rate.

The following services may not be reported as split/shared services:

• Critical care services-this is a Medicare rule.  Do not combine time for critical care services done by a physician and NPP, even when working in the same group, same specialty.
• Procedures are performed by one person.  Report under the NPI number of the clinician who performed the service.

Remember that physician supervision alone is insufficient for split/shared services, proper documentation is the key!

Janice Spaulding, CCS CPC

Auditor, Coding Educator Excite Health Partners

Telehealth: The Importance of Utilizing the System

Telehealth: The Importance of Utilizing The System

Telehealth is the use of communication technologies, to access healthcare services remotely and manage your healthcare. These may be technologies you use from your home to access information or a provider. Providers use telehealth technology to improve the care services you receive (physician to physician consultation). 

There are 3 types of Telehealth/Telemedicine.

1) Synchronous or real-time Video doctor to home visits

2) Asynchronous, (AKA Store-and-forward) where a patient collects medical information and then sends it to a care provider

3) Patient Monitoring, where patients use wearables to collect information which is sent to a care provider

The ability to bill for Telehealth services and out of state licensure has been an obstacle for the growth of Telehealth.  Laws mandating coverage /reimbursement for Telemedicine have passed in 42 states.  On October 3^rd, 2019, President Trump signed an Executive Order for Medicare Advantage (MA) plans to reimburse for Telehealth in 2020.  The American Telemedicine Association helps monitor telemedicine state policies and is working with others to help resolve licensure obstacles.

Telehealth is particularly beneficial for Americans with chronic clinical needs that require frequent visits to their physicians, primary care MD’s and behavioral health visits.  These are all areas were Telehealth has shown great strengths. Reducing remittance of patients with costly diagnosis such as CHF (Congestive Heart Failure) is also key to support a positive ROI.  Telemedicine has grown 250% from 2015 to 2017 and experts are predicting Telemedicine sector will grow into $130.5 Billion US Market by 2025, from the $21.2 Billion in 2018. 

Due to the complexities associated with implementation, Telehealth programs within large hospital systems often have difficulties utilizing the full services offered.  Frequently, Telehealth systems are developed by individual departments, resulting in virtual patient transfers to be difficult for providers. This virtual hand-off is required to help support each provider’s ability to work at their highest level of licensure.   It’s important to develop an implementation approach to ensure the Telehealth program meets the needs of the overall health system.  Workflows also need to be developed to address the acuity of the patient and the needs of the providers, while ensure charge capture is taking place. 

As with all Implementations stakeholder and champions are essential. Local coordinators/stakeholders also need to be engaged, trained and accountable so the system(s) can be effectively used and adoption can be sustained.   At the center of the implementation strategy should be the patient, followed by caregivers. Reports have shown Telehealth can increase patient and provider satisfaction, a goal that should be front and center.  Thus, the Telehealth implementation should be integrated with the overall patient engagement strategies of the health system.  

Excite Health Partners has the knowledge and experience to assist your organization ensuring your Telehealth program meets, and exceeds, your goals and expectations. We work with you to confirm your system can be sustained and thrive moving forward

Todd Klein

CIO VP of EHR Services & Digital Services

Sources: National Market & Global Market