Giving Credit for Exam Work?


Medicare says no split/shared evaluation for a consult.

Question: If an advanced registered nurse practitioner sees a patient for an inpatient consult and dictates: "See H&P notes and labs in chart" in her exam section, then only notes vitals and mental status exam, can I give her credit for work in the exam piece in the H&P when it was completed by another physician?

Answer: Is she billing a consult separate from the other physician? Or are they collaborating on the same day with one charge going out? If it's the former, and the other doc is using that H&P as part of his or her admit or other bill, then she can't use it. The work involved in performing the physical exam or any other part of a given visit belongs to that visit and its associated code, charge, and payment.

You can't "borrow" work that has been previously performed, claimed, and paid for and include it in a new code you are presenting for payment - it's double dipping.

If it's the latter case, and these two providers are collaborating with one bill going out, then reference Medicare's consult guidelines: "Carriers shall instruct physicians and qualified NPPs that a consultation service shall not be performed as a split/shared evaluation and management service."

Bill Dacey, CPC, MBA, MHA, is principal in the Dacey Group, a consulting firm dedicated to coding, billing, documentation, and compliance concerns. Dacey is a PMCC-certified instructor and has been active in physician training for more than 20 years. He can be reached at or

This question originally appeared in the February 2010 issue of Physicians Practice.


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