Wiki Need clarification of split/shared rules for procedures

[denisek1028]

I know the split/shared rules are confusing on the hospital side and I am hoping someone can help me. I know critical care and procedures cannot be split shared per CMS but if the APP performs the procedure (ex: laceration repair) and the MD signs off and does his "attestation" is this acceptable to bill under the MD or is the rule just that....procedures can't be split shared and the APP should be billing? I have the same question regarding critical care.

Thank you!

 

[jkyles]

Hi there, the good news (maybe?) is that CMS has withdrawn its guidance for split/shared and critical care services pending future rule making. https://www.cms.gov/files/document/enf-instruction-split-shared-critical-care-052521-final.pdf

 

[thomas7331]

The guidelines for billing split/shared visits only applies to evaluation and management services, not to procedures. All procedures performed in a hospital must be billed under the credentials of the provider who actually performed the procedure. (And even for an E/M service, 'signing off' and doing an attestation would not be sufficient to qualify for billing under the MD in a hospital setting - a split/shared visit is defined as one in which both providers perform a substantive portion of the E/M service.)