Healthcare Fraud Shield’s Latest Article: Are Two Providers Better than One?

1 Mar

What happens when a service performed on a patient is split or shared among more than one provider? I’d like to introduce you to a new modifier – modifier FS. According to AAPC Coder, modifier FS indicates that “the service was a split or shared evaluation and management (E/M) visit”.[1] While the modifier was created for Medicare, other payors may adopt this modifier as they see fit. 

How do I properly use modifier FS?

  • Only use for Evaluation and Management (E/M) Services performed and shared by both a physician and non-physician practitioner (NPP)
  • The physician and NPP should be part of the same provider group, but no longer required to be of the same specialty[2]
  • The services should be performed in a facility setting only

The shared visit (per CMS), except for critical care, should be reported under whomever performed the substantial portion of the service. What does most mean? It means more than 50% of the total time spent OR, and this is an interesting OR,  whomever performed and documented the entire history, exam or MDM. Therefore, whomever billed it must have conducted one of those components in its entirety.[3]

Split or shared visits are no longer allowed in an office setting, even if they meet incident-to rules, they are facility only so check your places of service.

What to look for?

  1. Provider excessively billing modifier FS
  2. More than one provider billing modifier FS for the same service
  3. Inappropriate place of service
  4. Upcoding, does the reason for the visit warrant the level of code billed?
  5. Has time been documented? Does the time count as qualifying time?
  6. Did one of the practitioners have face-to-face (in-person) contact with the patient?

If you have any questions or comments, please reach out to SIU@hcfraudshield.com.

References:

1 https://www.aapc.com/codes/hcpcs-modifiers/FS

2 https://www.cms.gov/files/document/r11181CP.pdf#page=18

3 https://codingintel.com/cms-shared-or-split-services/

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