Wiki Split or Shared Services

[aprilgaffney]

Hi Everyone!
Hoping someone can help give me clarification on Split or Shared E/M Services. I know that the provider with the higher MDM OR more than half of the time spent is who receives the "FS" modifier. My question is - if my provider only puts this statement "I made the patient's management plan, take responsibility for the patient management and have discussed treatment with APP today." in their attestation.... does that suffice? The APP has all of the documentation / MDM. There is some confusion on if just stating that they are taking responsibility, and creating the management plan is enough under these new 2024 "substantiate portion" guidelines. How would you code something like this? Would you give the credit to the Physician or the APP?

Thank you!

 

[Quaker]

Hi Everyone!
Hoping someone can help give me clarification on Split or Shared E/M Services. I know that the provider with the higher MDM OR more than half of the time spent is who receives the "FS" modifier. My question is - if my provider only puts this statement "I made the patient's management plan, take responsibility for the patient management and have discussed treatment with APP today." in their attestation.... does that suffice? The APP has all of the documentation / MDM. There is some confusion on if just stating that they are taking responsibility, and creating the management plan is enough under these new 2024 "substantiate portion" guidelines. How would you code something like this? Would you give the credit to the Physician or the APP?

Thank you!

Hi April - Have you ever figured this out? I sometimes see the same thing but not sure what to do. Although it seems to meet AMA CPT guidelines, I believe CMS would expect to see additional documentation by the physician noting what they did.

 

[jkyles]

I highly recommend checking with the specific payer or MAC. Here is what CMS has to say about MDM and documentation. https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/clm104C12.pdf

When MDM is used as the substantive portion, we believe each practitioner could perform certain aspects of MDM,
but the billing practitioner must perform the substantive part of MDM laid out in the CPT E/M Guidelines in order to bill the shared visit.

And doesn't go into detail for what is required for documentation.

E. Medical Record Documentation
Documentation in the medical record must identify the physician and NPP who performed the visit. The individual who performed the substantive portion of the visit (and therefore bills for the visit) must sign and date the medical record.

However, I have seen MACs that give more detailed guidance about what they want.