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Jan 15th, 2019 - Andrea58

Critical Care vs. Split Shared Services

Here is a question for the group concerning billing critical care services. The scenario is: a mid-level sees the patient in critical care. The physician comes into the room at some point with the mid-level. He takes over the service, performing the all aspects of the 99291, documents, makes edits to the mid-levels documentation, adding his own and signs off. I explained the nuances of the split-shared visits and that you cannot bill critical care as a split shared visit. The response back was it is not technically split/shared as the physician, he is doing all the work, just not needing to re-document all of the aspects of the note. The time billed in support of the code is his time only. The question presented to me was why, if he is acting independently, performing the visit and noting only his time, can't he bill the CC charge? The thought was perhaps there is an attestation that he might be able to use to clarify and support billing, by stating the visit was performed in entirety by the physician. i.e. "I personally and individually spent X amount of time with the patient performing.................... I presented the CMS guidelines. I need to be able to clarify for him why this does not or maybe there is a loop hole with the right attestation, I may be looking at this too strictly and he may be fine.

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