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 email@example.com or firstname.lastname@example.org.
This question originally appeared in the February 2010 issue of Physicians Practice.