I'm still not quite clear on this. OPPS governs how a facility reports and is paid for service, and that would be correct, the facility would report the total time spent providing critical care to that patient, regardless of the number of staff involved - since this is a facility/technical fee, the facility can only count the total time used in their facility. However, physicians are not paid under OPPS, they are paid under the PFS. The physician would still bill for their critical care services as a professional service. This would not be counting the time more than once since this is not a hospital or OPPS charge. The physician can and should bill for their services, and this would not have any bearing on how the hospital reports it, other than the fact that both entities would use the same medical record to support their charges, and not documenting would only hurt both of them.
You're correct that failure to document would be a quality issue. But I can't understand what the reasoning for doing this would be. The physician would be undercutting their own revenue by doing this and it would not benefit the facility's revenue at all. Or am I still missing something?