Wiki What determines face to face

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Lanie Christman

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I have a physician who works in conjunction with an NP (we have an Ortho walk-in clinic). On the days he's in the OR, he wants her to see the patient and do the history/exam. Once he's out of surgery-he will Skype the patient and determine the plan of care. I've read up on shared visits and understand that both providers must see and document their portion of the visit. My question is --does Skype justify "face to face" by the physician for his part of the case? I can't seem to find a definition for "face to face". Thank you for your help!!
 
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My opinion is, skype is not face-to-face, or else we wouldn't need telemedicine codes (because the visits would be considered the same as any other visit). Your scenario does not meet the criteria for telemedicine either.

Further, "Skype for Business" does have a BAA available, so you cannot use the free version of Skype, and you have to have signed the BAA with Microsoft, else it's not HIPAA compliant. HOWEVER, even with the BAA, Skype's infrastructure doesn't meet the technical criteria for HIPAA compliance. So that would be a no-go.
 
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I would also point out that shared visit rules do NOT apply to office visits. This seems like it should be billed under your NP.
 
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I agree these should go under the nurse practitioner--that's the fight I'm having with the provider.

The info provider below however, states that shared visits may be performed in the office setting.
The split/shared E/M visit policy applies only to selected settings: hospital inpatient, hospital outpatient, hospital observation, emergency department, and office and non-facility clinics. A split/shared E/M visit cannot be reported in the skilled nursing facility (SNF) or nursing facility (NF) setting.

When a non-hospital outpatient clinic or physician office E/M visit is split or shared between a physician and a NNP, the E/M encounter may be billed under the physician’s name and provider number if the patient is an established patient and the incident-to rules are met. (Note: Medicare clarifies that incident-to billing is not allowed for new patient visits).
 
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Your reference states "when a physician office E/M is split/shared between physician & NPP, the E/M may be billed under physician if the pt is established AND THE INCIDENT-TO RULES ARE MET."
1) Let's assume the carrier does follow incident to rules - not all do, only Medicare is a given. More and more carriers are not following incident to.
Incident-to is NOT met because the provider is not present in the suite. That's what I meant stating shared visits do not apply since the provider is not present. Sorry that was not clear.
The full reference from CMS claims processing manual is:
Office/Clinic Setting
In the office/clinic setting when the physician performs the E/M service the service must be reported using the physician’s UPIN/PIN. When an E/M service is a shared/split encounter between a physician and a non-physician practitioner (NP, PA, CNS or CNM), the service is considered to have been performed "incident to" if the requirements for "incident to" are met and the patient is an established patient. If "incident to" requirements are not met for the shared/split E/M service, the service must be billed under the NPP’s UPIN/PIN, and payment will be made at the appropriate physician fee schedule payment.
So, since incident to is unable to me met since the provider is not present, the service must be billed under NPP.
https://www.cms.gov/Regulations-and-Guidance/Guidance/Manuals/downloads/clm104c12.pdf
 
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