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Question:

Please explain the differences between incident to and split/shared visits.

Answer:
  • Incident to visits are permissible only in the office environment, and allow NPPs to bill for services under the supervising physician’s number, when specific supervisory and clinical requirements are met
  • Split/shared visits entail direct performance and participation by the physician under whose number the service will be billed. Split/shared visits may occur in either the office or hospital environment, although the concept generally applies more often in the hospital setting.

The concept of incident to billing in the office setting can apply in two ways:

  • It may apply to office services performed by ancillary staff during a physician’s E/M encounter (e.g., antibiotic injection by an RN) and included within the physician’s billing for the E/M service. o
  • It may apply to follow-up office E/M encounter for an established patient, performed by a NPP, subsequent to an initial E/M performed by a physician, and billed under the physician’s number. The original physician or a group member physician must be present and available in the office suite to provide oversight, and the record must reflect periodic oversight of the NPP’s plan of care. When the patient presents with a new problem(s), requiring changes to the plan of care, the visit again requires the physician’s direct participation.

Split/shared services are those in which both a physician and NPP actively participate, each fulfilling and documenting at least one required element of the E/M service. Split/shared services can be performed in either the office or hospital setting; the split/shared requirements apply to all services jointly performed by physicians and NPPs. A service performed in the hospital by an NPP alone must be billed under the NPP’s billing number. The concept of physician supervision without direct performance/participation does not apply to hospital services. Updated 10/17/2017.

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Insights
November 2018