Recent review of medical records has shown that there may be some confusion concerning what documentation is necessary when performing and billing for Split/Shared E/Ms Services. The following information is provided to assist physicians/Non-Physician Practitioners (NPPs) in the appropriate documentation of split/shared E/M services.
When an E/M service is performed in the hospital inpatient/hospital outpatient or emergency department and is shared between a physician and a NPP from the same group practice, the service may be billed as a split/shared E/M service. The split/shared service may be reported to Medicare using either the physician's or the NPP's Unique Physician Identification Number (UPIN), Provider Identification Number (PIN), and National Provider Identifier (NPI) number.
In order to report the service under the physician’s UPIN/PIN/NPI number, the physician must meet multiple requirements. Those requirements are:
If any of the above are lacking in the patient’s medical record, then the service may only be reported using the NPP's UPIN/PIN/NPI. Payment will then be made at the appropriate physician fee schedule rate based on the UPIN/PIN/NPI entered on the claim.
Please keep in mind that the following services may not be billed as split/shared services:If the E/M service is provided in the office/clinic setting and the E/M service is a shared/split encounter between the physician and the non-physician practitioner (NP, PA, CNS or CNM), then the service is considered to have been performed “incident to”, if the requirements of “incident to” are met, e.g., the physician has to do the initial evaluation and periodic evaluations to show that he or she is still involved in the case.
If "incident to" requirements are met, then the service can be billed under the physician’s UPIN/PIN/NPI. If they are not met, then the service must be billed under the NPP’s UPIN/PIN/NPI. Additional information on “incident to” requirements can be found online. Again, payment will be made at the appropriate physician fee schedule payment.
Other requirements that should be considered when billing for Split/Shared E/M services are: