Did you know in January of 2022, AMA updated the language for the definition of critical care services, CPT codes 99291 and 99292?
Direct delivery of care to a critically ill or injured patient when 1 or more vital organ systems are acutely impaired
A probability of imminent or life-threatening deterioration of the patient's condition exists, AND
High complexity medical decision making to treat a single or multiple vital organ system failure or to prevent further life-threatening deterioration of the patient's condition that requires your full attention
With this updated narrative and the continued confusion surrounding split/share critical care services, it is no wonder physicians and APPs continue to question if they are doing the right thing.
In the latest version of the CMS Medicare Learning Network publication from August 2023, additional clarification is provided for concurrent critical care services. According to their definition, concurrent care is when more than 1 individual provides services that are more extensive than consultative services at the same time. The services need to be reasonable and necessary in the active role of the patient's overall care.
They even clarify the roles further by clearly breaking down concurrent critical care into two categories: Concurrent care different specialties and concurrent care same specialties. See the CMS description below:
CONCURRENT CRITICAL CARE SERVICES: Different Specialties
Two providers can provide critical care services concurrently on the same date of service from more than one specialty to the same patient as long as the patient meets the criteria listed above and are not duplicative of each other. What this means is if you have a neurosurgeon and an intensivist managing the patient, it is expected that each provider is managing different critical care aspects of the patient and none of their care will overlap or duplicate.
CONCURRENT CRITICAL CARE SERVICES: Individuals in the Same Specialty & Same Group
When two providers within the same group practice are managing the patient on the same date of service, and the patient meets critical care criteria, those services can be reported and are billable.
Only one CPT code 99291 can be reported per day. The provider providing the initial critical care service is to report the 99291 for 30-74 minutes and any additional provider should document and report their time using the CPT code 99292 for additional time.
When 1 provider begins the critical care service but does not meet the time threshold needed to meet the 74 minutes, another provider from the same group can continue to deliver critical care services to the patient. In those instances, you would combine the total time providers spent to meet the required time for billing purposes.
Once you meet the cumulative time to report critical care services 99291, only an individual in the same specialty or group can report the 99292 when they provide an additional 30 minutes in critical care activities.
Remember all time that is spent on critical care visits must be medically necessary and meet the AMA definition of critical care.
So what does this mean for those encounters that could be viewed as split shared? According to the CMS definition for split share:
"A split (or shared) service is an E/M visit where both a physician and NPP in the same group each personally perform part of a visit that each 1 could otherwise bill if provided by only 1 of them. We pay the provider who performs the substantive part of the visit."
The easiest way to keep these differences straight is to look at it this way:
If the patient is seen throughout the day with one provider performing the initial critical care and other providers from the same group practice seeing the patient in follow-up activities throughout the day, this would constitute Concurrent Critical Care: Same Specialty.
If two provider from the same group are seeing the patient and perform parts of a vists, it becomes split share. The key word here is "part of a VISIT". Wikipedia defines visit as a "go to see for a specific purpose", this could be viewed a one and done visit. There is typically no follow-up throughout the day.
Resource:
CMS Evaluation and Management
MLN006764 August 2023
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