Split Shared -New change by cms in 2022

priceless

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Hi,
Can someone clarify the time based split shared billing.
Per CMS if PA and MD bill for split shared based on time, they must each document time spent.
But they also quote "When two or more practitioners jointly meet with or discuss the patient, only the time of one individual can be counted”.

So if PA and MD jointly see the patient, only 1 time statement from the billing provider should suffice, since the time overlaps for both providers.?

Thanks
 
Last edited:

haraml7

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My first thought is this Critical Care. If this is Critical Care you can add the times up and bill for the provider with the substantial amount of time (with FS modifier).
If this is an E/M then only one E/M per provider group can bill for that rendered service, and it would go to the provider that saw the patient with the substantial amount of time. So whoever saw the patient, and documented the most amount of time, that provider is who gets the credit for the E/M you select. This would apply only to inpatient visits though. Are these office visits or inpt visits. If these are office visits this would not apply and would fall under the incident to guidelines, which is another can of worms.
 

csperoni

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For split shared based on time, you may bill for the provider that spent >50% of the time.
If they are meeting together at the same time, you cannot count the same time for both providers.
Let me try to provide examples for clarification. In my real world, the most likely situation is the PA and MD see the patient face to face together, and the PA reviews some info before and completes some work afterward.
PA spend 16 minutes reviewing labs, other MD reports, etc.
PA and MD both personally see the patient - PA usually confirming some info. MD usually performing exam. They spend 10 minutes in patient room from 10:10a- 10:20a. During this time, MD tells patient and PA what additional tests/meds, etc should be ordered.
MD and PA leave the room, then PA spends 12 minutes ordering/charting.
So, you can count the 10 minutes for the MD (face to face time). For the PA, you cannot those same exact 10 minutes (10:10a-10:20a) because you counted them for the MD. You can count the 16+12 for PA = 28 PA minutes.
If the MD and PA are not performing any elements at the same time, you may count each of their individual time.
I know it won't be an option for 2022, but it is for 2021 to not use >50% of time, and instead choose either history, exam or MDM as the "substantive" portion. So in my situation, the MD performed the entire MDM and also the entire exam. I can bill under the MD even though the PA spent > 50% of time and will consider either MDM or exam the substantive portion.
I hope that helps and didn't muddy it even further for you.
 

priceless

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To clarify , both PA and MD are from same group and are billing inpatient admission for example 99223.
If both PA and MD log in different times, then the practitioner who has the substantive time bills.
I am trying to interpret "When two or more practitioners jointly meet with or discuss the patient, only the time of one individual can be counted”.
So 1 time statement from billing provider should suffice if both PA and MD jointly see the patient.
1 time statement makes sense since time will be same for both right?
 
Messages
352
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Hi,
Can someone clarify the time based split shared billing.
Per CMS if PA and MD bill for split shared based on time, they must each document time spent.
But they also quote "When two or more practitioners jointly meet with or discuss the patient, only the time of one individual can be counted”.

So if PA and MD jointly see the patient, only 1 time statement from the billing provider should suffice, since the time overlaps for both providers.?

Thanks
Hi there, both providers need to document their time and specify what they did so the practice can determine who performed the substantive portion of the visit.

That includes situations when the two providers jointly meet. This will allow whoever is reviewing the note to spot the overlap and bill appropriately.
 

csperoni

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If you are using time, and portions of their time are done jointly, both should have a time statement and how much was joint time.
From my example above:
MD: I spent a total of 10 minutes with PA examining patient and discussing treatment plan.
PA: I spent a total of 38 minutes (10 minutes with Dr. A) reviewing records, examining patient, and placing orders.
 
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