This webinar aims to elucidate the changes for the year 2024 concerning billing for shared and incident care services. Furthermore, it will delineate the requisite documentation requirements essential for both shared and incident care billing scenarios. By attending this webinar, healthcare providers can gain a comprehensive understanding of the evolving CMS policies and the intricacies of billing for shared and incident care. Armed with this knowledge, they can adopt proper billing practices and uphold the requisite documentation standards, thereby minimizing the risk of audits, paybacks, and reimbursement delays. Register, https://conferencepanel.com/conference/secrets-to-correctly-billing-shared-care-and-incident-to-services-in-2024

1. Solving the Mysteries And Changes
Around
Shared Care 2024
&
“Incident to”
Jan Rasmussen
PCS, ACS-OB, ACS-GI, ACS-EM
Professional Coding Solutions
janrpcs@aol.com

2. 2
Objectives
• Explore the difference between shared care and
“incident to” services.
• Recognize changes to shared care in 2024
• Review specific guideline for each service
• Understand reimbursement issues
• Define QHP providers versus clinical staff and
services they can provide
• Understand which services require orders
• Look at how other payers view these Medicare
policies

3. Basics
• All physician groups that employ QHPs may be faced with billing
Medicare for their services.
• The key issue is differences in reimbursement based on who reports a
service
– Services billed using the physician’s NPI are paid at a 100% of the
PFS rate
– Services billed using the QHP’s NPI are paid at 85% the PFS rate
• Huge compliance issue
• Failure to comply with the shared care and “incident to” rules can lead
to issues ranging from:
– Claims denials
– Overpayments /paybacks
– Future pre- and/or post-payment review
– False claims liability
• Lookback or statute of limitations of up to ten years).

4. QHP/NPP
• A QHP/NPP is a licensed health professional
• Recognized by Medicare as able to
evaluate/diagnose, treat and be paid for medically
necessary services on the Part B physician fee
schedule
– Qualified by education and training
• QHP must meet eligibility requirements to be
credentialed by Medicare and bill independently
• Examples: nurse practitioner, physician assistant,
clinical nurse specialist, certified nurse-midwife

5. Clinical Staff
• Person who works under the supervision of a
physician or other QHP professional
– Allowed by law, regulation and facility policy to
perform or assist in the performance of specific
professional services
– 99211 or specific code based on TOS
– Service billed under physician/QHP name
• Includes medical assistants, licensed practical
nurse, etc.

6. Split/Shared Care
• Shared or split services are Evaluation and Management (E/M) services
performed jointly but not concurrently between a physician and a non-
physician practitioner (NPP/QHP), in the same group, in a facility
setting.
• May not be performed in office setting (POS 11)
• Services may include both face-to-face and non-face-to-face activities.
• QHP/NPP is employed in the same group practice by the physician or
employed by the same employer
• Work must be performed on the same date of service
– Rounds at different times of day
• If a physician saw the patient in the morning and his partner sees
the patient later in the day for the same problem they would bill
one E/M service but they may combine the complexity of their
services and bill for the level of the joint visits.
• CMS requirements for split shared care in 2024 were supposed to be
based on total time to determine the “substantive portion”.

7. • Significant change in CPT and under the 2024 final rule.
– Substantive portion now either 50% of the total practitioner time or
substantive portion of medical decision making.
• History and physical exam no longer considered for “substantive”
portion of visit.
• Medical decision-making has 3 components:
• Number and complexity of problems addressed
• Amount and/or complexity of data to be reviewed and analyzed
• Risk of complications and/or morbidity or mortality of patient
management
– Based on CMD as the substantive portion a provider would have to
document all or 2/3rds of CMD to qualify as substantive portion.
• CMS feels MDM is not easily attributed to a single physician or NPP when the
work is shared, it is expected that whoever performs the MDM and
subsequently bills the visit would appropriately document the MDM in the
medical record to support billing of the visit
Split Shared Care…

8. CPT Split Shared Care…
• For the purpose of reporting E/M services within the context of team-
based care, performance of a substantive part of the MDM requires that
the physician(s) or other QHP(s) made or approved the management plan
for the number and complexity of problems addressed at the encounter
and takes responsibility for that plan with its inherent risk of
complications and/or morbidity or mortality of patient management. By
doing so, a physician or other QHP has performed two of the three
elements used in the selection of the code level based on MDM.
• If the amount and/or complexity of data to be reviewed and analyzed is
used by the physician or other QHP to determine the reported code level,
assessing an independent historian's narrative and the ordering or review
of tests or documents do not have to be personally performed by the
physician or other QHP, because the relevant items would be considered
in formulating the management plan.
• Independent interpretation of tests and discussion of management plan or
test interpretation must be personally performed by the physician or other
QHP if these are used to determine the reported code level by the
physician or other QHP"

9. Split/Shared Care…
• Activities that may be considered as part of substantive
time:
– Preparing to see the patient (for example, review of tests)
– Obtaining and/or reviewing separately obtained history
– Performing a medically appropriate examination and/or evaluation
– Counseling and educating the patient/family/caregiver
– Ordering medications, tests, or procedures
– Referring and communicating with other health care professionals (when not
separately reported)
– Documenting clinical information in the electronic or other health record
– Independently interpreting results (not separately reported) and
communicating results to the patient/family/caregiver
– Care coordination (not separately reported)

10. Incident to Requirements
• Performed in physician office
• Physician provides direct supervision
o Physician must be present in the office suite and immediately available to
furnish assistance and direction throughout the performance of the
procedure.
o Supervising physician can be any physician in the clinic
o Does not have to be same physician that initiated care
• If auxiliary personnel perform services outside the office setting, e.g., in
a patient’s home or an institution (other than hospital or SNF), their services
are covered incident to a physician’s service only if there is direct supervision
by the physician [e.g., the physician must be physically present to oversee the
care].
• PHE temporarily changed direct supervision rules to allow the supervising
professional to be remote and use real-time, interactive audio-video
technology, instead of requiring the physician’s physical presence.
o Extended flexibility until December 31, 2024

11. Documentation
• Identity of performing provider
• Note indicating name of supervising/billing
physician was in the office suite at the time
of the service.
• Preferable to have physician order available
that ordered follow up by QHP or ancillary
service

12. Register Now