You may have seen a couple of recent Documentation and Compliance Tips published on the NAMAS blog authored by health law attorneys who have had some opinions regarding Incident To and Shared Visits in the office/clinic space. These opinions do somewhat contradict how we have taught Incident To service and Split Shared service in place of service 11. I thought I would help clarify what our opinion is on this topic.
First, I would like to express how grateful we are that we have health law attorneys who are willing to be contributing authors at NAMAS. We do not feel that any information that they’ve provided, in either article, was incorrect or invalid. They are the specialists, they are the subject matter experts in that area of health law. What we do want to point out is there are two different ways to approach things; what is the most compliant way so we are proactive and what can we defend?
I think what both health law attorneys have helped us to see is there is a leg of defendability when it comes to the visits in which a physician and a mid-level provider perform those services together. I thought Mr. Baker did a really good job in his article of expressing that these are referred to as “shared visits” because you’re familiar with that term. But technically, we could call them “co-visits”. Mr. Glazer referred to them as “collaborative visits”. Yes, there may be the ability to have a defense there, however, maintaining propriety on compliance and making sure that we are being one-hundred percent on the side of best practices for compliance, we would recommend that you not run out and change how your organization is treating and seeing those patients for Incident To services.
Again, we want to express, that defending that position may absolutely be possible, but for best practices, Incident To adheres to the Incident To rules. It is a service that should be rendered, but it’s Incident To the physician as opposed to a combined service with the physician.
If you have any questions, please feel free to reach out to both of those health law attorneys, but also know that I’m here. Anytime you see something and you have questions, pop me an e-mail. You never know what I’m going to do a video or blog about it! You can reach me through the namas@namas.co e-mail, or you can e-mail me directly at sdeconda@drsmgmt.com.
Your next steps:
- Watch the YouTube video of Shannon discussing this topic on the NAMAS YouTube channel and subscribe to get notified when new auditing and documentation tips drop.
- Contact NAMAS to discuss your organization’s coding and documentation practices.
- Read more blog posts to stay updated on the 2023 Revisions to the 2021 E&M Guidelines.
- Check out the agenda for the 15th Annual NAMAS Auditing & Compliance Conference and register to attend!
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