Wiki Critical Care and FS Modifier

[jocarter]

I can't find guidance on this specific scenario:

First provider is a Physician and documents 35 minutes of critical care, second provider is mid-level and documents 74 minutes of critical care. Would you combine all of the time and bill the 99291 and 99292 under the mid-level provider (since that is who did the substantive amount of work) with the FS modifier- OR- would you bill the 99291 under the physician and the 99292 under the mid-level?

Seems like we would be looking revenue by billing the 99291 under the mid-level if we bill combining all time together.... Just wanted to get feedback on what others are doing in this scenario... I did look on multiple different coding platforms and also on Coding Intel and I can't find anything with this example.

Thank you,

Jolene Carter CPC, CPMA, CRC, CGSC

 

[ldickerson58]

I found this info on CodingIntel website.

• Bill the service under the provider number of the practitioner who provided the substantive portion of the service.
• The substantive portion of the service may be determined by either who spent >50% of the time or the practitioner who documented in its entirety history, exam or MDM. Since history and exam are not key components, it is difficult to know what the “entirety” is.
• CMS had two proposals related to critical care. The first, mentioned above, is that a physician and NPP in a group may share critical care services. This is a change from their current policy. I’m going to call their new policy a win/lose situation. Yes, you can add together the time of the physician and NPP (win) but you must bill it under the practitioner who has spent the most time (lose, if it’s an NPP, because it’s paid at 85% of the physician fee schedule.)

 

[jkyles]

I can't find guidance on this specific scenario:

First provider is a Physician and documents 35 minutes of critical care, second provider is mid-level and documents 74 minutes of critical care. Would you combine all of the time and bill the 99291 and 99292 under the mid-level provider (since that is who did the substantive amount of work) with the FS modifier- OR- would you bill the 99291 under the physician and the 99292 under the mid-level?

Seems like we would be looking revenue by billing the 99291 under the mid-level if we bill combining all time together.... Just wanted to get feedback on what others are doing in this scenario... I did look on multiple different coding platforms and also on Coding Intel and I can't find anything with this example.

Thank you,

Jolene Carter CPC, CPMA, CRC, CGSC

Hi there, for split/shared critical care services you report everything under the provider who did the substantive portion (more than 50% of the time) with modifier FS. In your scenario it is the NPP.
https://www.cms.gov/files/document/r11288cp.pdf