Wiki 2024 Split or Shared Visits

[MelodyCPC]

After reading through the 2024 CPT E/M Services Guidelines, I have more questions than answers in regard to the newly added section regarding Split or Shared Visits. These CPT rules for team-based E/M services could be fairly significant for practices that have NPPs working with a supervising physician that approves and accepts responsibility for the management plan and I think that this is a relatively common scenario. Selecting the billing provider for payers that do not follow CMS Incident To and Split (or Shared) Visit guidelines or haven't implemented their own policies could become interesting with this new guidance! The new section doesn't address what E/M categories this concept applies to (office and hospital?) or whether each provider must have a face-to-face with the patient, etc.

What are your thoughts on this? How do you plan to implement this in your practice? How will you keep it all straight as far as applying CMS guidelines to those applicable payers and CPT guidelines for all others?

 

[Dinaerwin]

I am struggling with the documentation requirements of the MD when coding Hosp Pro- fee visits. Does the MD Need to state "I performed mdm in its entirety"? If he agrees with the plan of the mid-level, can you use any RX
management performed by the mid-level (not done on this example)?

 

[MelodyCPC]

I am struggling with the documentation requirements of the MD when coding Hosp Pro- fee visits. Does the MD Need to state "I performed mdm in its entirety"? If he agrees with the plan of the mid-level, can you use any RX
management performed by the mid-level (not done on this example)?

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The Claims Processing Manual has not yet been updated for 2024 and the MAC's do not seem to be recognizing the new AMA CPT guidelines for split/shared, so it is a concern until those sources are updated. According to the Final Rule, you can follow AMA CPT and the provider who "approves" the management plan and "takes responsibility" for the plan and risks associated with the plan, can be the billing provider. All elements in the MDM can be used to select the level of service, with the exception of independent interpretations or discussions with other providers about the management plan or test interpretations must be performed by the billing provider. In 2023, the billing provider would have to perform all MDM in its entirety, but in 2024 they should not have to.

 

[jkyles]

I am struggling with the documentation requirements of the MD when coding Hosp Pro- fee visits. Does the MD Need to state "I performed mdm in its entirety"? If he agrees with the plan of the mid-level, can you use any RX
management performed by the mid-level (not done on this example)?

Hi there, it will depend on the carrier. CMS rules are stricter than CPT guidelines. In the 2024 final physician fee schedule Medicare stated that whoever bills the visit must personally perform and document the substantive portion of MDM (problem and risk).

Although we continue to believe there can be instances where MDM is not easily attributed to a single physician or NPP when the work is shared, we expect that whoever performs the MDM and subsequently bills the visit would appropriately document the MDM in the medical record to support billing of the visit.”

I haven't seen any requirements for a separate statement about performing MDM. I think the FS modifier covers that.

Betsy Nicoletti has a great, free, article here: https://codingintel.com/cms-shared-or-split-services/

I also recommend checking your MAC. It may have issued a more detailed policy based on the the 2024 updates.