Requirements for Billing Split/Shared Visits

In my last post, I discussed changes to the CMS physician fee schedule. One of these changes was for split/shared visits, which will now be an option for critical care services and certain visits occurring in skilled and non-skilled nursing facilities. Previously these were excluded from split service billing.

This brought up the question of what exactly is a split service? Often confused with incident-to billing as they have some similarities. Both types of visits require collaboration between a PA or NP and a supervising physician. How they differ is in the setting that they apply. Split services occur in an inpatient setting, whereas incident-to is in an outpatient setting.

An organization might bill split/shared visits because it allows 100% reimbursement of the physician fee. If billed under the NPI of the PA, reimbursement will be at 85% of the physician fee.

For this type of service to be billed, the PA and supervising physician must be employed by the same organization. Second, the services they provide must occur on the same day. The part that makes it difficult to bill out as a shared visit is that each must provide documentation that they saw the patient. A cosigned chart note does not count. The physician must separately document that they have seen and examined the patient.

In practice, it might be good to have two people checking on the patient from a billing perspective is a lot of burdensome documentation. The best care for the patient and the use of time to get a few extra dollars when billing is two separate issues. It might be best to see the patient multiple times a day by different providers, but that does not mean an exam is completed by both providers and documented.

The important thing to keep in mind with these visits is that the correct documentation is done. A cosigned note is not enough; complete documentation is required.