Question: Can we bill split visits by physician and NPP as service by the physician? Does office setting impact billing of shared visits?
New Mexico Subscriber
Answer: Medicare payment policy defines a split/shared E/M as an encounter where the physician and a qualified non-physician practitioner (“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. Medicare allows only certain types of services to be reported as shared between a physician and NPP. Medicare also limits the setting in which the shared visit may be reported. The Medicare Claims Processing Manual, Chapter 12, Section 30 indicates shared visits apply to “hospital inpatient, hospital outpatient, hospital observation, emergency department, hospital discharge, office and non facility clinic visits, and prolonged visits associated with these E/M visit codes.” Also keep in mind, “the split/shared E/M policy does not apply to critical care services or procedures.” In a hospital setting, if your physician performs a face-to-face encounter, you can bill the service for the physician or the NPP. If your physician only reviews the clinical record and discusses the case with the NPP, you bill the service to the NPP.
When your physician and an NPP are involved in care of an individual patient, you can count it as a shared or split visit. If the service was performed in an office setting and ‘incident-to’ requirements are met, you can bill the service for the physician under the ‘incident to’ provision rules. If these criteria are not met, report the service under the NPP’s NPI number.