Wiki Is this attestation adequate for split/shared visit?

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betsycpcp

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This is in Florida - the visit was performed by an APRN. The note is signed by her and also signed by the physician. The only documentation from the physician says "ATTENDING PHYSICIAN: I PERSONALLY REVIEWED PATIENT'S CHART AND WENT OVER THE PLAN OF MANAGEMENT FOR THIS PATIENT. I AGREE WITH THE PLAN ABOVE." In the same paragraph it lists changes to prescriptions for hydrocodone, methadone, duloxetine, tizanidine and says scripts were sent electronically. It doesn't explicitly say this was done by the physician, but he probably did it - I looked up the license of the nurse practitioner and it says she is not a controlled substance prescriber. Is this enough documentation for the visit to be billed under the physician? The current CPT guidelines say the billing physician has to take responsibility for the risk, etc - does that have to be explicitly stated?
 
jkyles said:
Hi there, this doesn't show that the physician's MDM exceeds the NP's.
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I agree, but I'm looking at the CPT manual E/M guidelines where it says the physician has to make "or approve" the plan "for the number and complexity of problems addressed" and takes responsibility for the plan with its inherent risk of complications etc. It says in doing so, the physician has performed 2 of the 3 elements used in the selection of the code level. I'm not sure how to determine that he approved the plan "for the number and complexity of problems addressed" - in other words, what does the physician's portion of the note have to include to show he meets the requirements?
 
In your example, it isn't even clear if the attending physician actually saw the patient. It says they reviewed the chart and agree. In my opinion, no amount of medical decision making clear, let alone the substantive portion. "Probably" ordered the prescriptions is not a clear demonstration to bill under the physician. For this situation, I would only bill under the APRN. If this is a recurring issue, and the physician actually performed the majority of the service, this is an education opportunity for documentation improvement.

E/M: Service-Specific Coding: Split/Shared Billing

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I would just add a couple of thoughts:
1. Trust your "spidey-senses." If you can't tell if the documentation makes the grade, it's a safe bet that it doesn't.
2. On the compliance side of things, I highly recommend reminding the providers that documentation related to controlled substances must be absolutely clear. I'm sure the prescription from the physician in your EHR, but the doctor also needs to say something like "after reviewing the chart, I issued prescriptions for X, Y, Z," so there's no question if your charts are ever audited.
 
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