Wiki Split/Shared Critical Care 2022

[RhondaJohnson]

Hello,

With the new split/shared services modifier FS that applies to critical care, I have a question regarding when and when not to use the FS modifier. We told our critical care PA's and NP's to stop documenting their CC time years ago, because the MD was also documenting critical care time, and we were unable to bill split/shared cc services. Well now we can start billing split/shared services. Not all PA's and NP's have been educated on this yet, so sometimes we see the MD document and bill CC time, he references the PA or NP's note, but the PA or NP does not document any CC time. Do we append the modifier FS in those instances? Both saw the patient, but only the md documents CC time, and so billing is based entirely on the MD's note.

We have some people saying we should append the FS even when the mid-level does not document CC time, just to indicate they both saw the patient on that date.

Any ideas on this? It doesn't seem right to append modifier FS when the mid-level has no time documented that is being used for billing.

 

[jkyles]

Hi there, this is a toughie.

Under the split/shared rule both providers must document their time because that determines whether the service is billed by the physician or the NPP. CMS created modifier FS to allow them to track split/shared visits for facility-based/critical care services. So it sounds like those are split/shared visits and should be reported with FS, but in some cases you won't have documentation that establishes who should bill it.