Evaluation and Management FAQs

Urgent Care

  1. Please explain the concepts of split/shared and incident to E/M services in the urgent care setting.

    Answer:
    The urgent care setting is defined by CMS as a nonfacility setting. This means the split/shared concept does not apply. The vast majority of E/M services in the urgent care setting are new patient visits, and incident to guidelines do not apply to episodes of initial outpatient E/M care. When a patient does receive subsequent care for the same problem in the urgent care setting and there is no change to the initial plan of care established by the original provider, incident to billing may be permissible when all other elements of the incident to rules have been met.

    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 the substantive portion of the 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).

Revised 4/15/2024