Unveiling the Secrets of Shared Care and Incident To Billing in 2024

As the pages of 2023 turn and the new year arrives, healthcare compliance bodies are also ready to introduce many other changes. Current CMS changes to their shared care policy have added to the confusion for physicians and other professionals. Hence, it's imperative to understand the incident to billing guidelines 2024 and incidents to. Let's explore this article to unveil the upcoming changes in 2024.

Understand "Shared Care" and "Incident To" in Billing

Shared care, involving multiple healthcare professionals collaborating to manage a patient's treatment, requires clear communication, defined roles, and coordinated efforts. In 2024, advancements in technology may further facilitate this collaboration through integrated health information systems, allowing seamless sharing of patient data among providers while ensuring compliance with privacy regulations.

Furthermore, Medicare Part B's payment policy outlines a scenario known as a split/shared E/M visit. This happens when a physician and a qualified NPP both participate in a necessary patient encounter on the same service date. They each make significant contributions, engaging in face-to-face interaction with the patient, which involves aspects of history, examination, or crucial medical decision-making related to an E/M service. Importantly, for this to qualify as a split/shared visit, both the physician and the qualified NPP must belong to the same group practice or be employed by the same employer.

Understanding "incident to" billing remains crucial in healthcare. This practice permits non-physician practitioners to bill for services under a physician's supervision at the physician's rate of reimbursement. However, specific guidelines govern "incident to" billing, requiring the supervising physician's presence in the office suite and direct involvement in the patient's care plan. When coding for incident-to-services, modifiers are unnecessary; standard CPT, HCPCS, and ICD codes suffice. Medicare reimburses incident-to-services by NPPs at the total fee schedule amount, provided correct coding is employed. Nevertheless, billing guidelines for incident-to-services differ among commercial payers and Medicare.

CMS's 2024 Shared Or Split Services Policy

In 2024, both CPT and CMS brought in some big changes for split/shared services. CPT clarified that who spends more than half the time or is involved in making important medical decisions determines the main part of these services. CMS agreed with this idea, saying that the practitioner who puts in over half the time or is making those key medical decisions should decide the substantial part, dropping the need for recording complete exams or history, which matches what CPT says. But here's the tricky part: CMS delayed using just time to decide until 2025, and this is the third time they've postponed this. They stressed the need to properly document the medical decision-making when the work is shared, whether it's face-to-face or not.

Interestingly, services billed by a doctor get paid more compared to those billed by non-physician practitioners. For Medicare, shared services can only happen in certain places, mainly in a facility setting. While CPT doesn't say much about where these services should be, Medicare demands using a specific code to identify shared services in evaluations and management. Also, there's a bit of a wording difference between CPT and CMS when it comes to describing certain healthcare professionals like APRNs and PAs in the CPT book's E/M section.

Decreased Conversion Factor and  Lower Payment Rates For Physicians by CMS

CMS has decided to cut payments to physicians for the second consecutive year. In the CY 2024 Physician Fee Schedule (PFS), there will be a 1.25 percent reduction compared to CY 2023. Physicians and healthcare professionals working under Medicare Part B receive payments for various services, such as office visits and surgical procedures, based on the resources typically used for these services. This calculation involves Relative Value Units (RVUs) for physician work, practice expenses, and malpractice.

To determine payments, CMS multiplies these RVUs by a "conversion factor." In 2024, CMS has finalized a 3.4 percent decrease in this conversion factor. This reflects the finalized 2023 factor of $33.06, adjusted by an RVU budget neutrality of -2.20 percent and the 1.25 percent increase provided by the CAA 2023.

As per the final decision, the conversion factor for 2024 stands at $32.74, a decrease of $1.15 from the 2023 figure of $33.89. This means that most physician services will receive lower payments in 2024 compared to 2023, barring specific services where CMS has altered the RVUs or finalized payment increases.

Medicare And Medicaid Provider And Supplier Enrollment Policies Update

CMS possesses the authority to revoke or deny enrollment for Medicare providers or suppliers based on various grounds, such as non-compliance with enrollment requirements or termination from other federal health programs. Under specific conditions, CMS can suspend a provider's billing privileges instead of revoking them when a lesser penalty suffices.

Notably, CMS has decided against the proposal to revoke enrollment due to misdemeanor convictions of managing employees or organizations within the past decade. Instead, CMS introduces new grounds for revoking enrollment, including civil judgments related to the False Claims Act and failure to meet enrollment standards.

In addition, CMS introduces a novel enrollment status termed "stay of enrollment," allowing for a temporary pause in enrollment before any deactivation or revocation occurs. Furthermore, all Medicare provider and supplier types are now mandated to report any changes in their practice locations, additions, or deletions within a 30-day timeframe.

Key Takeaways

Staying updated with the secrets to correctly billing shared care, latest regulations, documentation requirements, and compliance standards is vital for healthcare professionals navigating shared care and "incident to" billing in 2024. Continuing education and regular training sessions can aid in mastering these complex processes while ensuring ethical and accurate billing practices.

Moreover, emphasizing patient-centered care remains paramount as the healthcare landscape continues to evolve. Encouraging patient engagement, ensuring transparency in billing practices, and providing comprehensive care while navigating shared care arrangements can significantly enhance patient outcomes and satisfaction.