General Surgery Coding Alert - 2022 Issue 7
Billing: Find Clarification on Observation Care for Shared Billing
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Article Overview
This article summarizes Medicare guidance discussed in a CMS evaluation and management update webinar and focuses on split/shared billing in facility-based care. It is intended for coders, billers, compliance staff, and clinicians who document and report evaluation and management encounters. The article covers how the updated rules apply across different facility-based services, how documentation should reflect shared participation, and how Medicare guidance addresses timing, billing responsibility, and record support.
Why This Topic Matters
Split/shared billing affects how facility encounters are documented and reported, so a clear understanding of the current Medicare framework helps organizations reduce claim errors and support medical review readiness.
Article Sections
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Remember Split/Shared Visit Rules Changed for Facilities
Introduces the facility-based split/shared framework and contrasts it with office-based reporting. It explains the general setting where the guidance applies and the provider types involved.
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Define ‘Substantive’ for Accurate Payment
Discusses the concept used to determine which contributor is recognized for the visit. It also addresses the role of work components and time in the broader context of evaluation and management services.
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Keep Modifier FS in Mind
Covers documentation and reporting considerations tied to split/shared services in facility settings. It places the discussion in the context of evaluation and management encounters within hospitals and outpatient facilities.
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Apply Split/Shared Rules to Observation, Critical Care, Consults
Reviews the additional service categories addressed by the updated guidance. It also discusses provider participation, admitting authority, and related facility-based considerations.
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Identify Those Who Split/Share Services in Documentation
Focuses on documentation expectations for shared encounters and record support. It emphasizes how the medical record should reflect multiple contributors and related attestation practices.
What You Will Learn
- How Medicare split/shared billing guidance applies in facility-based settings
- Which broad E/M encounter types are addressed by the update
- What documentation elements should support a shared encounter record
- How provider roles and participation affect reporting and recordkeeping
- Which Medicare guidance sources are referenced in the discussion
Who Should Read This
- Medical coders
- Billing staff
- Compliance professionals
- Physicians
- Nurse practitioners
- Physician assistants
- Revenue cycle teams
Modifiers Discussed
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