Wiki Split / Shared billing questions

bethb

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Good afternoon. I think at this point, I have confused myself and possibly am overthinking the split/shared billing concept.

We have a specialist group that sees patients in the hospital. Many times, the NPP (PA-C) and the M.D. both documentation all of the required elements and we can determine the correct billing provider - however, neither provider has their name / time stamp beneath their portion of the documentation. (I believe this is being addressed with the providers in the group) At the end of all of the documentation, the providers' names are both listed with their credentials and electronic signatures. Our billers have some concerns about split / shared billing because neither provider labels their part of the medical note. (We can distinguish the NPPs part and the M.D.s part because the M.D. titles their part of the note as "Attending Addendum" but without any other identifying information) So for this issue, we are unsure if we can report the service under the NPP solely (NPP signature is at the end of the note) and if we can report the service under the NPP, would we still use the -FS modifier? If anyone has any insights, I would greatly appreciate any suggestions. We have all thoroughly read the CMS policy, or local MAC guidelines and the CPT guidelines. Thank you.
 
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