Inpatient Compliance: Split/Shared Services

Why This Topic Matters

Understanding split/shared billing affects whether an inpatient E/M service can be billed under the physician, how the encounter must be documented, and whether the setting qualifies for this type of reporting. The article is relevant for reducing compliance risk and aligning billing practices with CMS guidance.

Article Sections

1. Overview of split/shared services

   Introduces the concept of split/shared E/M services in the inpatient setting and contrasts it with a related billing policy used in other settings.

2. CMS definition and substantive involvement

   Summarizes the CMS framing of split/shared services and discusses the general requirement that both providers contribute to the encounter.

3. No limit on NPP decisions

   Covers the relationship between the physician and non-physician provider, including general expectations about the care plan and physician participation.

4. Eligible E/M codes

   Lists the categories of E/M services that may be considered for split/shared reporting and notes related service categories that are excluded.

5. The 'who' and 'where' for split/shared services

   Describes the provider relationships and facility-based settings associated with split/shared services, including references to hospital billing contexts.

6. Properly documenting split/shared services

   Explains the documentation framework, including contributor attestation, combined record support, and signature expectations.