2023年澳门开奖结果记录

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2023年澳门开奖结果记录
Practice Management

Reporting Split/Shared E/M Visits in 2024

Beginning January 1, 2024, the Centers for Medicare & Medicaid Services (CMS) will implement a new split (or shared) evaluation and management (E/M) billing policy for E/M visits provided in part by a physician and in part by a nonphysician practitioner (NPP). The billing provider for such visits will be the physician or NPP who furnished the 鈥渟ubstantive portion鈥 of the visit. CMS defines 鈥渟ubstantive portion鈥 to mean more than half of the total time spent by the physician or NPP performing the split/shared visit or the substantive part of the medical decision making (MDM) during the split/shared visit.

What is a split/shared E/M visit?

A split/shared visit is an E/M visit in a hospital or other facility setting that is performed in part by both a physician and an NPP who are in the same group practice. A split/shared E/M visit may be provided to a new or established patient for an initial or subsequent visit.

Can a split/shared E/M visit be reported in a nonfacility setting?

No. This new split/shared E/M visit reporting policy applies only to those furnished in a facility setting. In a nonfacility setting, such as a physician鈥檚 office, different reporting rules apply when an NPP provides some or all of an E/M visit and the physician bills for the visit. This type of E/M visit is referred to as an "incident-to" service.

Who is considered an NPP?

Medicare defines an NPP as a nurse practitioner, physician assistant, certified nurse specialist, or certified nurse midwife. All of these practitioners may independently report E/M services if they are legally authorized and qualified to furnish an E/M service in their state. NPPs who care for Medicare patients in a facility must enroll in the Medicare program to bill for the services they provide.

How does Medicare define “same group” for the purposes of reporting a split/shared E/M visit?

CMS has yet to provide a definition of "same group" at this time, but has indicated that a physician and an NPP must work jointly to furnish all of the work related to the E/M in circumstances when a split/shared visit is appropriately billed. If a physician and NPP are in different groups, the physician and NPP would be expected to bill independently and only for the services each fully furnishes.

How is it determined who should report a split/shared E/M visit?

CMS has adopted the following Current Procedural Terminology (CPT) guidelines for reporting a split/shared E/M visit:

If the physician or other QHP1 performs a substantive portion of the encounter, the physician or other QHP may report the service. If code selection is based on total time on the date of the encounter, the service is reported by the professional who spent the majority of the face-to-face or non-face-to-face time performing the service. For the purpose of reporting E/M services within the context of team-based care, performance of a substantive part of the MDM requires that the physician(s) or other QHP(s) made or approved the management plan for the number and complexity of problems addressed at the encounter and takes responsibility for that plan with its inherent risk of complications and/or morbidity or mortality of patient management. By doing so, a physician or other QHP has performed two of the three elements used in the selection of the code level based on MDM. If the amount and/or complexity of data to be reviewed and analyzed is used by the physician or other QHP to determine the reported code level, assessing an independent historian鈥檚 narrative and the ordering or review of tests or documents do not have to be personally performed by the physician or other QHP because the relevant items would be considered in formulating the management plan. Independent interpretation of tests and discussion of management plan or test interpretation must be personally performed by the physician or other QHP if these are used to determine the reported code level by the physician or other QHP.2

Physician Solo Time

NPP Solo Time

Physician & NPP Joint Time

Who Reports Split/Shared Visit

15 minutes

10 minutes

10 minutes

Physician reports (15 of 25 total minutes)

15 minutes

10 minutes

10 minutes

15 minutes 10 minutes 10 minutes Physician reports (25 of 35 total minutes)

10 minutes

15 minutes

10 minutes

NPP reports (25 of 35 total minutes)

10 minutes

10 minutes

10 minutes

Either the physician or NPP may report since the total time is the same for both

When reporting a split/shared visit using time, what activities count toward total time?

CMS relies on the list of activities included in CPT E/M Guidelines that count toward total time for purposes of who reports the split/shared visit and for the level of code selected. Based on these guidelines, physician/NPP time includes the following activities:

  • Preparing to see the patient (such as review of tests)
  • Obtaining and/or reviewing separately obtained history
  • Performing a medically appropriate examination and/or evaluation
  • Counseling and educating the patient/family/caregiver
  • Ordering medications, tests, or procedures
  • Referring and communicating with other health care professionals (when not separately reported)
  • Documenting clinical information in the electronic or other health record
  • Independently interpreting results (not separately reported) and communicating results to the patient/family/caregiver
  • Care coordination (not separately reported)

Physician/NPP time does not include the following activities:

  • Performance of other services that are reported separately
  • Travel
  • Teaching that is general and not limited to discussion that is required for the management of a specific patient
Some of the activities that may count toward the total time of a split/shared E/M visit are face-to-face services. Does CMS require that both the physician and NPP have a face-to-face encounter with the patient to report a split/shared E/M visit?

No. For all split/shared E/M visits, only one of the practitioners must have face-to-face (in-person) contact with the patient, but it does not necessarily have to be the practitioner who performs the substantive portion and bills for the visit. When reporting a split/shared visit using total time, the substantive portion could be provided entirely with or without direct patient contact and will be determined based on the proportion of total time, not whether the time involves direct or in-person patient contact.

If the physician/NPP who provides the substantive portion is determined by time, is the E/M code level selection also based on time?

Yes. If code selection is based on total time on the date of the encounter, the service is reported by the physician/NPP who spent the majority of time performing the service.

What are the documentation requirements for a split/shared visit using time?

CMS has not yet released specific documentation requirements for reporting a split/shared E/M visit. However, it is best practice that the medical record identify the two practitioners who performed the split/shared visit, the activities each practitioner performed, and the time spent by each practitioner. In addition, the individual who performed the substantive portion鈥攁nd therefore bills the visit鈥攎ust sign and date the medical record. CMS has emphasized that, although any member of the medical team may enter information into the medical record, only the reporting provider may review and verify notes made in the record by others for the services the reporting clinician furnishes and bills.

What are the documentation requirements for a split/shared E/M visit using MDM?

The new split/shared E/M visit guidelines indicate that performance of a substantive part of the MDM requires that the physician or NPP who will bill the visit made or approved the management plan for the number and complexity of problems addressed at the encounter and takes responsibility for that plan with its inherent risk of complications and/or the morbidity or mortality of patient management. By doing so, a physician or NPP has performed two of the three elements used in the selection of the code level based on MDM.

Is a modifier required when reporting a split/shared visit?

Yes. CMS requires that HCPCS modifier 鈥揊S (Split or shared E/M visit) be appended to the facility claims for split/shared E/M visits, no matter if the physician or NPP bills for the visit. This modifier does not apply to incident-to office visits.

Can critical care services be reported using time or MDM?

No. Critical care E/M services (e.g., CPT codes 99291-99292) are reported based solely on time. MDM is not a component of these CPT codes.

Please note that the reporting details above are suggestions only and should not be construed as official coding/billing rules.

References

1 CPT, in general, refers to NPPs as other qualified healthcare professionals (QHPs). With respect to reporting split/shared services in a facility setting, NPPs and other QHPs are synonymous.

2 2024 CPT Codebook, pg. 6.

All specific references to CPT codes and descriptions are 漏 2023 American Medical Association. All rights reserved. CPT is a registered trademark of the American Medical Association.