shared visit and discharges

Both CRNP & MD see pt on day of discharge. Only CRNP writes amount of time she spent on it. Can we still bill under MD as shared visit?


  • edited May 2017
    Time based codes cannot be billed as a shared service. The time documented has to be provided and documented by the MD.


    Todd Thomas, CPC, CCS-P ERcoder, Inc
    President 941 NW 164th, Suite 1 Edmond, OK 73013
    (405) 749-2633

  • While true in regards to E/M services involving residents, that is incorrect in regards to NPPs.

    CMS does prohibit one E/M type—Critical Care codes—from being "shared" between a physician and NPP (billed based on the combination of physician and NPP time), but no general prohibition exists in regards to physicians and NPPs sharing other time-based E/M codes. Quite the opposite: the Claims Processing Manual specifically mentions “hospital discharge” services and “prolonged visits”—two E/M categories which are ALWAYS time-based—as examples of E/M categories that may indeed be shared by a physician and NPP.

    From the Internet-only Claims Processing Manual (100-04), Chapter 12, Section 30.6.13 (H), found on p. 80 here:

    The split/shared E/M visit applies only to selected E/M visits and settings (i.e., hospital inpatient, hospital outpatient, hospital observation, emergency department, hospital discharge, office and non facility clinic visits, and prolonged visits associated with these E/M visit codes). The split/shared E/M policy does not apply to critical care services or procedures.

    In the situation presented, as long as the MD documented a note detailing his/her performance of a “substantive portion” of the in-person part of the E/M (i.e., the substantive portion cannot be comprised of key decision-making by the MD after discussing the situation with the NPP in the hallway outside the presence of the patient), and the time documented by the NPP by-itself is enough to exceed 30 minutes, then reason dictates that the combination of their time would have of course exceeded 30 minutes, and the requirements for billing 99239 as a shared service have been met.

    Seth Canterbury, CPC, CPC-I
    Clinical Data Quality Education Department
    University of Florida Jacksonville Physicians, Inc.
    653 West Eighth Street
    Tower I, Suite 606
    Jacksonville, FL 32209

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