We are getting conflicting information on split-shared evaluation and management (E & M) visits in the hospital. The Medicare information I have found says that a consult code cannot be split-shared. But our question is this: If the patient has Medicare and we cannot bill the consult code, can that visit be split-shared if the intent was a consult?


As you say, Medicare no longer covers consultations; therefore, the consultation guidelines do not apply regardless of the intent. For hospital visits, Medicare will cover an initial visit as well as subsequent visits.

For the initial visit, codes from the “initial hospital care” code series 99221–99223 would be the appropriate category. Before Medicare abolished the use of consult codes, these codes were used only by admitting physicians, as Medicare would only pay for one initial hospital visit; they were commonly referred to as “admission codes.”

However, the CPT® definition has always been “initial hospital care” to reflect that any provider seeing patients in the inpatient hospital setting should use a code from the 99221–99223 series for their initial inpatient visit. After Medicare abolished the consult codes, they had to give providers a billing alternative, and they now no longer limit the use of this series to only the admitting physician. Medicare will now cover one initial visit per specialty. The providers should use the code series 99231–99232, subsequent hospital care, for follow-up visits during the same admission.

Split/shard services are allowed by Medicare for the codes from these two series (initial and subsequent hospital care). However, the providers splitting/sharing the service should each document their own separate note detailing their portion of the service. The physician cannot simply “attest” to the advanced practitioner’s (or other provider’s) note. Documentation from the two notes should be combined to select the appropriate level of service.

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CPT is a registered trademark of the American Medical Association.