Question: I understand that we can bill for shared encounters (between the ED physician and a mid-level provider) under the physician's PIN if the physician documents a -clinically meaningful face-to-face encounter.- Our group uses the T-system, and in a situation like this, how would an auditor discern who made the marks? How can we document this kind of encounter sufficiently?
Indiana Subscriber
Answer: Don't rely on defending -who made the marks- when deciding whether you can use the physician's personal identification number (PIN). Instead, concentrate on getting an attestation from the physician showing that he had a meaningful bedside encounter with the patient.
This documentation should outline the fact that the supervising physician participating in the shared visit had a face-to-face encounter with the patient.
For example, for a patient with abdominal pain, an appropriate attestation would be the following: -Patient seen and examined, abdomen tender, will check CT scan.- See Medicare Transmittal 1776 for the complete CMS rules on this issue.