July 7, 2016

Question:
In our office, the physicians use our PA as they would residents. The PA sees the patient first, performs an examination, and then discusses the case with the physician. The physician also sees the patient, but doesn’t repeat everything the PA has done. Can this be reported in the physician’s name?

Answer:
It depends. This scenario is termed a split/shared visit, because neither the PA nor physician did everything; they each performed a portion of the work and combined it. In the office setting, incident to rules must be considered before applying split/shared rules, which do not allow an NPP and a physician to combine their work when it is performed and individually documented on the same day. If the patient has an established problem, with a plan of care that was set previously by a physician, then the combined work can be reported in the physician’s name, and it will be allowed at 100 percent of the physician rate. However, a new patient or a new problem cannot be reported as split/shared for the combined work. One option is to report the visit in the PA’s name and accept 85 percent of the allowable; alternatively, the visit can be reported in the physician’s name, but only for the work that the physician performed.

Keep in mind, Medicare and other payers use place of service code 11 to designate services performed in a physician office. In academic- and hospital-based settings, a physician may instead use place of service code 19 or code 22, which are handled differently.

*This response is based on the best information available as of 07/07/16.