05/05/2022

CMS 2022 Changes to Documentation Guideline

CERNER FLASH FROM ONE MCLAREN

 CMS 2022 Changes to Documentation Guidelines

2/1/2022

Split / Shared Services:

Impacted Areas: Physicians with NPs & PAs in hospital (POS [Place of Service] 21), outpatient surgical centers or hospital departments (POS 22), Emergency Departments (POS 23), Inpatient Psychiatric Facilities (POS 51), Inpatient Rehab (POS 61), Skilled Nursing Facilities (POS 31), and Provider Based Clinics

[POS 19 off- campus locations; POS 22 for on campus locations]

Non-Provider-Based Clinics are excluded (POS 11). Effective: 1/1/2022

CMS' 2022 Final Rule includes changes for documentation guidelinesfor Split / Shared Services as of 1/1/2022 and now has new clarification that requires adjustment to documented statements.

Resource link for details: https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2022-  medicare-physician-fee-schedule-final-rule

Split/shared services are no longer supported by a basic physician attestation such as, “I have personally seen and examined the patient, reviewed the PA’s history, exam, and MDM and agree with the assessment and plan as written.”

CMS' 2022 Final Rules now requires:

• To bill Split/Shared under a Physician, the documentation must support one of the following:

Physician performed more than 50% of the time of the visit. However, the government has now clarified this language and indicates that it is looking for the actual time involved in care by the NP/PA and the physician not just the statement that it is more than 50% of the visit time.

OR

• Physician performed any one of the following three components in its entirety: the history, exam, and/or medical decision making (MDM) o Level of service cannot be higher than the key component documented by the physician allows o For example, if physician documents detailed exam for initial hospital visit and this component is used to support a split/shared service, the level of service cannot be higher than 99221. (There are criteria for the level of exam, ROS, etc. for billing at each level per prior CMS guidelines which are still in place.)

o Details about key components for each level (and whether need detailed, comprehensive, etc.) can be found here: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-

Network-MLN/MLNProducts/Downloads/eval-mgmt-serv-guide-ICN006764.pdf o Billing provider (physician) must sign and date o New Modifier FS is used to identify split/shared services.

• When billing in Cerner, the modifier can be added to the billing code in a dropdown menu (see screenshot on last page).

 Recommend physicians document complete assessment and plan to support substantive portion of MDM (medical decision making).

• Physician signature and date will support a split/shared visit billed by the physician.

o You must document under your own login to capture documentation under the physician.

Split/Shared Physician Documentation Recommendations:

1. When documenting time for split / shared billing as the NP or PA:

NP and PA statement would use the autotext : .attestNP_PA_TimeCMS2022 ; "I have personally seen and examined the patient, performed the documentation and the assessment and plan as written. Number of minutes spent on the visit: [        ].”

When performing more than 50% of the visit and documenting time for split shared billing as the Physician (MD/DO):

"I have personally seen and examined the patient, reviewed the documentation and agree with the  assessment and plan as written.  Number of minutes spent on the visit: [           ].” In Cerner this can be inserted using autotext  .attestPhysicianNP_PA_TimeCMS2022

**Please note that the time would need to be documented by the NP / PA and by the physician separately in their documentation. The physician time would have to exceed the NP / PA time to meet the standard.

2. When performing history, exam and/or MDM in its entirety:

"I have personally seen and examined the patient and reviewed the documentation. I have performed the history /exam / MDM in its entirety per my documentation."

* Physician would include the history, exam and/or MDM as applicable when performed. Only one is required.

You can adjust the statement to reflect what you have done (delete the part of the phrase that you did not do). In Cerner this can be inserted using autotext  .attestPhysicianNP_PA_MDM_CMS2022

**Next year, in 2023, Medicare will move to time-based documentation ONLY to support split/shared visit billing. The billing provider will be the individual who documents the most time spent with the patient.**

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SOUTH/SOUTHEAST

BILLING BUZZ SPOTLIGHT

Hear ye, Hear ye!

Presenting the fabulous South/Southeast Chapter officers!! We are here and ready to serve our chapter and the MMBA with exciting meetings and interesting industry content to share.

Previous Meeting Topics:

• 2022 Telehealth Guidelines for BCBSM Confirmation
• Cosmetic Surgery- Gluteal Transfer
• Social Determinants of Health and HCCs

Upcoming Meeting Topic:

Credentialing with Gwen Davenport

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SOUTHEAST CHAPTER OFFICER