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