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vcar

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Hi all,

In the facility setting if a NP sees an in-patient and documents all of the HPI, exam and MDM in the EMR progress note. Later that day the physician "sees" the patient and attaches an attestation that states " Patient examined, Chart reviewed, Discussed with R.N. Nurse practioners note and orders reviewed, appropriate changes made." The MD makes no additional documentation to the progress note outside of the attestation.

Is this a shared visit??? I say no. Documentation guidelines state BOTH the physician and NPP must document the portion of the work they performed. I have a doc that is adamant all he needs to do is attach his attestation to the NPPs note to qualify as a shared visit. Am I taking the documentation guidelines to literal?

Thanks
 
Which documentation guidelines are you referring to? The CMS guidelines on split/shared services that I'm familiar with (from the Medicare Claims Processing Manual, Chapter 12) say:

"When a hospital inpatient/hospital outpatient...or emergency department E/M is shared between a physician and an NPP from the same group practice and the physician provides any face-to-face portion of the E/M encounter with the patient, the service may be billed under either the physician's or the NPP's UPIN/PIN number. However, if there was no face-to-face encounter between the patient and the physician (e.g., even if the physician participated in the service by only reviewing the patient’s medical record) then the service may only be billed under the NPP's UPIN/PIN."

By my interpretation, since the physician has documented performing a face-to-face service, this would meet the requirements as stated by Medicare. However, I do agree that documenting they physician's own work and findings would hold up better in an audit than an attestation, especially if the physician uses exactly the same verbiage in every attestation. CMS and the OIG have made clear that they consider the use of canned statements that are the same for every patient and do not contain any individualized an information to be inappropriate use of the EHR.
 
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Thanks Thomas - I was hoping you'd reply. I am referring to CMS guidelines. This particular provider does use the exact same wording on every single attestation. It never differs and there is never any additional documentation by him in the progress note other than the attestation. Knowing CMS and OIG's stand I'm concerned about an audit.
 
Another similar post asked me to share a source on this, so I thought it might be useful here too. This is the CMS fact sheet on EHR use which contains what I think is a pretty emphatic statement on page 2 under 'Cloning': "The medical record must contain documentation showing the differences and the needs of the patient for each visit or encounter. Simply changing the date on the EHR without reflecting what occurred during the actual visit is not acceptable." There are additional link at the end that may be useful for additional research.

https://www.cms.gov/Medicare-Medica...ownloads/docmatters-ehr-providerfactsheet.pdf

Hope this helps some.
 
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