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CMS spells out split/shared visit rule now that consults are no longer payable

CMS spells out split/shared visit rule now that consults are no longer payable

CMS spells out split/shared visit rule now that consults are no longer payable


In addition, CMS reps cite present Medicare law and says that practices should report just one inpatient care code per patient, per day.

Even though CMS has done away payment for consult codes, it will continue to honor split/shared visits as long as they are billed using E/M codes and follow the payment rules already in place.

That's the word from CMS where staffers wanted to do away with the confusion stemming from the January MLN Matters article SE1010, which offered various questions and answers regarding how to bill Medicare following the elimination of consult code payment. CMS spells out split/shared visit rule now that consults are no longer payable


Here, CMS noted that "the split/shared rules applying to Evaluation/Management services remain in effect, including those cases where services would previously have been reported by CPT consultation codes."

CMS's Rebecca Cole noted during an April 13 CMS Open Door Forum, "We understand that this has led to some confusion, as there were and are different split/shared rules for consultation services compared to E/M services."

"We would like to clarify that Q&A," said Cole. "As we are no longer recognizing the consultation CPT codes for purposes of payment under Part B, the split/shared rules regarding consultation services are no longer applicable. Since Evaluation/Management visit codes are being billed for services that were previously reported by the CPT consultation codes, the split/shared rules pertaining to E/M services apply when billing E/M CPT codes," stressed Cole.

Do not forget: You can still report shared/split visits as per the regulations using E/M codes; however you cannot collect from Medicare for any consultation codes.

CMS is thinking about issuing a clarification in writing to do away with any confusion pertaining to the shared/split billing rule, noted Cole.

CMS Asks Practices to Rein in Initial Inpatient Billing

One caller wanted clarification on billing for hospital care now that consult codes are not payable. She asked whether a physician can go for two initial hospital care codes for the same patient on the same date for example, if the physician saw the patient before surgery for one reason, and then saw the patient post surgery for another reason.

"I think you should consult the CPT rules in addition to the manual, however I think our reaction to that is no," CMS's William Rogers, MD, said during the call. Rogers said that the initial hospital care codes refer to that physician's first visit with the patient. He advised that later evaluations should be billed by means of subsequent hospital care codes.

On the other hand, CMS reps pointed to the fact that they'll look into the issue further to find out whether doctors should be able to report a second initial hospital care code if specifically requested to review a different condition. "We can think about this further and decide what our next steps will be," Rogers said. Until then, CMS staffers urged practices to continue billing according to published rules. CMS spells out split/shared visit rule now that consults are no longer payable


In black and white: Both initial inpatient hospital care codes and following hospital care codes are per diem' services and may be reported only once a day by the same doctor or doctors of the same specialty from the same group practice," CMS Transmittal 1545 notes.

Use Present Bone Density Codes

One caller was happy that, owing to the new health care reform legislation, CMS will be boosting payment for bone density tests, but said that the legislation listed old bone density test codes 76075 and 76077. He enquired whether MACs will be requesting those codes going forward, or whether practices should continue going for new codes 77080-77082.

Advice: You should use the present codes 77080-77082 and not the old ones, CMS's Amy Bassano said.
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CMS spells out split/shared visit rule now that consults are no longer payable Ann Arbor