Medicare Compliance & Reimbursement

Question: My physician and a physician’s assistant visited the same patient in the hospital on the same day. Can I bill this as a shared service?

Answer: The answer is yes, if the documented services meet the Medicare rules for collaborative shared services. This means that the NPP provided the history, exam and MDM and the physician then also provided face-to-face service while documenting a critical portion of the service related to the patient’s chief complaint.

Example: The service provided by the NPP was part of a pre-round for the physician. Then the physician can focus on the problem when she has her face-to-face with the patient.

Following CMS’s shared-visit rules, you can bill claims under the physician’s NPI number as long as the physician provided face-to-face time with the patient and documents a significant component of the service. If no face-to-face time is provided by the physician, the service can only be billed under the NPP’s number, lowering the reimbursement.

A shared-visit claim needs to provide the following details:

• A medical record that identifies both providers.
• A connection between both providers’ encounter notes.
• Legible signatures of both providers.
• Proof that the physician provided at least one element of the encounter.

Keep in mind: The documentation must show that the physician was personally involved in some way by conducting an exam and/or planning the care of the patient.