Physician and NPP Split/Shared Billing: Compliance, Reimbursement and Physician Compensation Challenges

Course Details
- smart_display Format
On-Demand
- signal_cellular_alt Difficulty Level
- work Practice Area
Health
- event Date
Wednesday, December 7, 2022
- schedule Time
1:00 p.m. ET./10:00 a.m. PT
- timer Program Length
90 minutes
-
This 90-minute webinar is eligible in most states for 1.5 CLE credits.
This CLE webinar will guide healthcare counsel on the use of nonphysician practitioners (NPPs) and the associated issues. The panel will address the 2022 Medicare Physician Fee Schedule (MPFS) guidance on split/shared billing. The panel will also discuss compliance and documentation considerations as well as physician compensation considerations. The panel will offer best practices for mitigating risk when using NPPs.
Faculty

Mr. Dugger provides clients with effective and practical counsel informed by the various environments in which he has practiced. With more than 20 years of experience, he has a proven ability to achieve positive results within the highly regulated health care industry.

With more than 25 years of experience in healthcare documentation and revenue cycles, Ms. Howard possesses a deep understanding of the intricacies of healthcare coding compliance and documentation. She regularly performs coding, billing and revenue cycle reviews to ensure accuracy and compliance for clients. Working with hospital systems and physician practices of all sizes, these reviews have included evaluation and management, inpatient and outpatient ambulatory services. Additionally, Ms. Howard has worked on corporate integrity agreements and self-disclosure projects, as well as performing as an expert witness in criminal fraud defense.

Ms. Wink assists clients in the analysis of general health law matters and regulatory issues, including accreditation, certification, licensure, billing and payment, compliance, Medicare appeals, fraud and abuse and Stark. She advises a variety of healthcare clients including healthcare systems, hospitals, group practices, diagnostic centers and long-term care facilities. Ms. Wink chairs the Medicare Issues Committee for the Wisconsin chapter of the Healthcare Financial Management Association and is a frequent speaker on regulatory issues. Prior to practicing law, she was a manager in the audit department of KPMG and was a member of KPMG's Healthcare Practice Group.
Description
CMS implemented new requirements for split/shared billing in the MPFS and, as a result, brought renewed attention to the use of NPPs. Under the new MPFS, the availability of split/shared billing is expanded and split/shared visits are billed under the provider who provided the substantive portion of the services.
Medicare reimburses services provided by physicians at a higher rate than those same services provided by NPPs. The new regulations lay out the requirements for a physician or NPP to bill a split/shared visit in a hospital or other healthcare facility. The rule expands the circumstances under which a healthcare professional can bill for services performed in part by another practitioner. The rule also includes limitations on billing for a split/shared visit.
It is important for healthcare providers who use split/shared billing, or may use it in the future, to understand the changes and update their policies to ensure they are consistent and compliant with the new rules.
Listen as our authoritative panel of healthcare counsel examines the use of NPPs and the associated issues. The panel will address the 2022 MPFS guidance on split/shared billing. The panel will also discuss compliance and documentation considerations as well as physician compensation considerations. The panel will offer best practices for mitigating risk when using NPPs.
Outline
- Use of NPPs: trends
- 2022 MPFS guidance and Medicare requirements
- Split/shared care
- Substantive portion of the visit
- Documentation
- Physician compensation considerations
- Best practices
Benefits
The panel will review these and other key issues:
- What are the split/shared documentation requirements?
- How does the use of NPPs impact the Stark employment exception for services personally performed by the physician?
- What best practices should healthcare providers and their counsel employ when using NPPs to ensure Medicare and regulatory compliance?
Unlimited access to premium CLE courses:
- Annual access
- Available live and on-demand
- Best for attorneys and legal professionals
Unlimited access to premium CPE courses.:
- Annual access
- Available live and on-demand
- Best for CPAs and tax professionals
Unlimited access to premium CLE, CPE, Professional Skills and Practice-Ready courses.:
- Annual access
- Available live and on-demand
- Best for legal, accounting, and tax professionals
Related Courses

The ACA and the New Administration: CMS Proposed Rule Impacting Marketplace Eligibility and Other Notable Actions
Tuesday, April 22, 2025
1:00 p.m. ET./10:00 a.m. PT

Healthcare Speaker Programs and AKS Compliance: Regulatory Update, Lessons Learned From Recent Settlements
Tuesday, May 27, 2025
1:00 p.m. ET./10:00 a.m. PT

HIPAA and Beyond: Health Information Privacy Updates
Tuesday, May 27, 2025
1:00 p.m. ET./10:00 a.m. PT
Recommended Resources
Navigating Modern Legal Challenges: A Comprehensive Guide
- Business & Professional Skills
- Career Advancement