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Urgent Care

  1. Are split/shared E&M visits permissible in an urgent care facility (POS 20)?

    Answer:
    The concept of split/shared visits applies when both a physician and NPP actively participate and document joint performance of an E&M service. The concept of split/shared billing may apply in the urgent care setting; in order to bill the service under the physician’s NPI, both the physician and NPP must perform and document at least one required element of the service.

    Incident to billing does not apply in the urgent care setting; a NPP cannot perform a service independently and bill the service under a physician’s NPI, even when the physician is available in the urgent care suite. Care provided in the urgent care setting is generally intended to address a new patient problem, requiring all elements of care to be completed by the performing/billing provider, whether that provider is a physician or a NPP. Since urgent care is episodic in nature, a plan of care is not maintained and subsequent care for a persistent problem is also considered episodic.

    Initial patient encounters (which are the norm in the urgent care setting) may be performed by either a physician or NPP, but must be billed by the performing provider. An NPP may contribute to the encounter, but in order to bill the service with the physician’s NPI, the physician would need to personally perform and document at least one essential element of the E&M service. When an NPP performs the full service in an urgent care encounter, the service must be billed by the NPP. During an encounter by either a physician or NPP, contributory incident to services may be performed by clinical office staff (e.g., vital signs or medication administration). Updated 1/8/2018

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