ED Coding and Reimbursement Alert

Reader Question:

The CMS Shared Services Documentation Exemption Only Applies to E/M Services

Question:

If an emergency physician sees a patient and performs an ED E/M service, but has a Non Physician Provider come in to perform a laceration repair and both provider's properly document in the chart, and sign the chart, do the E/M and procedure get billed under the physician, or does the E/M get billed under the physician and the procedure under the Non Physician Provider? Also, does it make a difference depending on the payers the bill is being sent too?

Texas Subscriber

Answer:

The physician can't bill for a procedure performed by the NPP. The changes from Transmittal 1776 and the rules regarding shared services only apply to E&M services. There is no mechanism for a procedure to be reported as a shared service. Procedures performed by an MLP should be billed under their ID number and paid at 85% of the Medicare allowable.

The resident rules for procedures do not would apply to NPP services. Most private insurers require that the bill for services provided by NPP be filed under the physician's name and provider number. A few private insurers want the claim to be filed under the NPP name, specifically Aetna and some BCBS have stated that they will be following Medicare policy for documentation and performance requirements as well as applying the 15% discount.