In theory I would say yes.
The problem I see is you still have to have the counseling/coordination piece greater than 50% to use time. So they both have to actually have face-to-face contact with the patient and document what they did in order to do the split/shared under the doctor. Then we have meet the time requirements. I would also be concerned if the documentation supported them both doing the same or very similar things then you would run into medical necessity issues.
It would depend on the documentation as to my comfort level with this.
Sorry probably not the easy answer you were looking for but this is what I would look for.
Laura, CPC, CPMA, CEMC
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