Message From Your Region 3 Representatives | March 2019
I want to share information from a wonderful AAPC chapter meeting I attended in Region 3, Lexington, Kentucky, on August 21, 2018. I was fortunate to catch a presentation by Patricia Hendricksen, MS, CHCA, CPC-I, CPC, CCP-P, ACS-PM. Patricia is highly acclaimed, and was my coding teacher back in 2005, when I sat for my CPC (and passed the first time, thanks to Pat!). Her topic was Nonphysician Practitioner (NPP) Documentation. She shared the following table, which I found helpful and concise.
Medicare’s “Incident-to” vs. “Split/Shared” Visits
|1||General Information||INCIDENT-TO VISIT
Physician Office Setting (POS 11)
Hospital Setting (POS 19, 21, 22, 23)
|2||Definition||Services are furnished as an integral, although incidental, part of the physician’s personal professional services in the course of diagnosis or treatment of an injury or illness||A medically necessary encounter with a patient, where the physician and a qualified NPP each personally perform a substantive portion of an E/M visit face to face with the patient on the same date of service|
|3||Allowed Settings/Place of Service Codes (POS)||· Office-Established Patient (POS 11)||· Hospital Inpatient (POS 21)
· Hospital Outpatient & Observation (POS 19, 22)
· Emergency Department (POS 23)
|4||Non-allowed Services/Settings (POS)||The following types of encounters are NOT eligible for Medicare incident-to billing:
· Office visit: New Patient (POS 11)
· Office visit: Established patient with a new problem (POS 11)
· Consultation services (any setting): 99241-99245
· Hospital Inpatient/Outpatient visits: (POS 22,21,19)
· Emergency Dept: (POS 23)
|The following types of encounters are NOT eligible for Medicare split/shared billing:
· Consultation services (any setting): 99251-99255
· Critical Care services (99291-99292). Medicare does not permit split-shared “critical care” visits.
|5||General Requirements||· The service provided must be reasonable and medically necessary, must be within the NPP’s scope of practice, as defined in state law where he/she practices; and performed in collaboration with a physician.
· NPP must be salaried or employed by (or independent contractor) the physician, physician’s group, or physician’s employer.
· Supervising physician must be physically present in the same office suite and be immediately available to render assistance if that becomes necessary.
· An office/clinic must have identifiable boundaries when part of another facility; services must be furnished within the identifiable boundary.
· Physician performed the initial service and subsequent services of a frequency which reflect his/her active participation in and management of the course of treatment.
· Documentation: the professional identity of the staff furnishing the service must be documented and legible. A physician co-signature is helpful to demonstrate on-site supervision.
· Incident-to note by NPP: the NPP note should indicate the reason for the visit, services provided, reference the Attending MD’s care plan of MM/DD/YYYY and follow-up plan, any discussions with the MD, and the name of the on-site supervising MD.
· Only one note is required: NPP’s
|· The service provided must be reasonable and medically necessary, must be within the NPP’s scope of practice, as defined in state law where he/she practices; and performed in collaboration with a physician.
· Physician & NPP are from the same group practice or employed by the same Group employer. NPP must be credentialed and able to bill independently through the Group. (Either person may bill, but not both.)
· Physician provides a face to face portion of the E/M encounter with the patient. NOTE: If physician only participated in the service by reviewing the patient’s medical record, then the service must be billed under the NPP’s NPI#.
· Split/shared visit may not be performed as a consultation service in any setting.
· Documentation: it is NOT sufficient for MD to state “seen and agree” or countersign the NPP’s note without a separate physician note. Physician must specifically document what services he/she has personally provided.
· Shared/Split Visit Note by MD
· Two Separate notes required: NPP & MD notes.
|6||CPT Codes||CPT 99211-99215 established patient, office visit||· 99201-99205, New outpatient
· 99211-99215. Established Outpatient
· 99281-99285, Emergency Visit
· 99217, Observation Care Discharge
· 99218-99220, Observation Care, per day
· 99221-99223, Initial Hospital Admission
· 99231-99233, Subsequent Hospital Care
· 99234-99236, Obs or Inpt Hospital Care
· 99238-99239, Hospital Discharge Day Mgmt
· 99354-99359, Prolonged Services
Hope to see you at HEALTHCON!
Dianne Estes CPC, CPB
AAPC National Advisory Board 2018-2021
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