Wiki E/M Determination between MD and APRN

ceebugg14

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We have been having a discussion within our office with different providers and billers to try to determine the outcome of this needed situation.

Our office providers routinely go over to the local hospital to round on inpatient and outpatient cardiac patients. Mostly, the APRN or PA does the visit summary and progress note. The MD physician will then come behind the APRN and provide an attestation to this progress note. In this attestation, the physician will then either state whether they did or did not contribute in more than 50% of this patient's care and discussion. The APRN will list (sometimes) in the "physical exam" portion of the progress note whether the physical exam was performed by the APRN or the MD.

If the attestation states the MD provided more than 50% of the care, but the APRN did not state the MD did the physical exam, would this be billed under the APRN or the MD?

Additionally, if the MD states in the attestation they did not spend more than 50% of time of the care, but the APRN did state the MD did the physical exam, would this be billed under the APRN or the MD?

Our APRN's state, regardless of the attestation, the only determination whether to bill under the APRN or the MD is the "physical exam" and if the progress note does not state the MD did the physical exam, it would be billed under the APRN.

Our MD's state the attestation is the only determination of whether to bill under the APRN or MD, and if the attestation states the MD provided more than 50% of the care, it is billed to the MD, even if they are not listed under the physical exam.

Can someone please shed some light on this situation so we can all be on the same page in the office? They are now looking to me to provide final determination and documentation on the matter.
 
If the PA and MD are in the same group and performing a split/shared E/M in a facility setting, then it sounds like the Split or Shared Visit policies/guidelines apply. You should review the Medicare Claims Processing Manual (Pub 100-04, Chapter 12, Section 30.6.18) and check with your MAC to determine appropriate documentation requirements and how to determine who can be the billing provider. The current policy does not require both providers nor the billing provider to have a face to face with the patient, so the exam is not a required element for the billing provider to perform. The determining factor is substantive portion - either based on who performed greater amount of the time spent or the medical decision making.
 
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