Debra,
I have been thinking about the consults for the last couple of days and re-thinking my statement. Traditionally, we could refer to CMS for rules on split/shared billing. The "split/shared" rule was/is a Medicare concept. Now that Medicare doesn't recognize consultation codes, it's made me re-think if commercial carriers still refer to CMS' former guidelines on split/shared rules for consultations. I've seached for CPT Assistant articles, endlessly, trying to find some language that follows this concept but I've come up empty handed.
Now...if the commercial carrier DOES follow CMS' policy on shared/split, then the answer is easy...(MLN bulletin).
Q. How should E/M services previously reported by CPT consultation codes and provided in a split/shared manner be billed?
A. The split/shared rules applying to E/M services remain in effect, including those cases where services would previously have been reported by CPT consultation codes.
I know that many carriers hold Medicare as the "golden standard"; however, I have to wonder just how many carriers actually have a solid policy on this.
So this has prompted another question. If the commercial carrier in question does not credential the mid-levels, this is probably a moot point and the split/shared concept isn't applicable. However, if a payer pays differently, depending who provides the service...NPP versus MD, the split/shared concept could become an issue.
I think this is one of those areas that has become muddy and the only resolution I see is to contact each payer and question their policy on split/shared consultations.
I'd love to hear other comments/thoughts...