As modifier -FS approaches its third year of active status, it’s important to understand the correct application of this modifier, which dictates payment for split/shared E/M visits. Since its introduction by CMS in January 2022, the modifier has become crucial for accurate billing, helping to prevent overpayments, underpayments, and compliance issues. Here are key tips for successfully using modifier -FS based on the latest Medicare Part B claims data and expert advice from top organizations.
Key Considerations for Using Modifier -FS
Modifier -FS is used for split/shared services, which occur when both a physician and a qualified healthcare professional (QHP) contribute to a patient’s care during a single visit. To ensure accurate billing, follow these essential guidelines.
Understand the Substantive Portion Definition
It is critical that all practitioners adhere to the most recent CMS definition of the “substantive portion” of a split/shared visit. This definition has changed multiple times, so staying up-to-date ensures compliance. “Make sure to use the most recent definition to avoid any compliance issues,” advises Vice president of reimbursement and professional practice at the American Academy of Physician Associates.
Documenting the Split/Shared Visit
Accurate documentation is vital for modifier -FS claims. The medical record must clearly identify both the physician and QHP involved in the visit, and the practitioner performing the substantive portion must sign and date the record. FS modifier must be reported on facility claims, regardless of whether the physician or QHP bills for the service.
Physician Documentation Tips
For full reimbursement and accurate modifier -FS reporting, physicians must do more than just sign off on a QHP’s note. Physicians should clearly document their approval of the treatment plan and their acceptance of responsibility for the patient’s care. Additionally, any independent interpretation of data or consultations with external physicians should be documented.
Choosing the Substantive Portion: MDM vs. Time
CMS allows practices to choose whether to determine the substantive portion of a visit based on medical decision-making (MDM) or time. While time-based reporting is often preferred, some services require the substantive portion to be determined based on MDM. For example, emergency department E/M services (CPT codes 99282-99285) must be calculated using MDM, as time is not considered for these codes. For other visits, practices should refer to the code’s full descriptor to decide which method—MDM or time—is appropriate.
Know When Not to Use the Modifier
It’s essential to avoid appending the -FS modifier to inappropriate codes. Medicare Part B data indicates that some practices have incorrectly used the modifier for services like blood draws and anesthesia. Ensure that the -FS modifier is only used for valid split/shared E/M visits.
Conclusion
Modifier -FS plays a pivotal role in ensuring accurate reimbursement for split/shared E/M visits. By following these expert tips, including proper documentation and correct determination of the substantive portion based on MDM or time, practices can maintain compliance and avoid billing errors.
Frequently Asked Questions (FAQs)
Q: What is the purpose of modifier -FS?
A: Modifier -FS is used to indicate a split/shared E/M visit, where both a physician and a qualified healthcare professional (QHP) contribute to the patient’s care. It is essential for accurate billing and reimbursement.
Q: How do I know who performed the substantive portion of the visit?
A: CMS allows practices to determine the substantive portion based on either medical decision-making (MDM) or time. Review the code’s full descriptor to determine the appropriate method.
Q: What are the documentation requirements for modifier -FS?
A: The medical record must clearly identify both practitioners involved in the visit. The practitioner who performs the substantive portion must sign and date the medical record. Additionally, the physician should document approval of the treatment plan and any independent interpretation of data.
Q: When should the -FS modifier not be used?
A: The -FS modifier should not be used for services such as blood draws or anesthesia, as these are not considered split/shared E/M visits. Ensure the modifier is only used for appropriate codes.
Q: Can modifier -FS be applied to all E/M services?
A: No. Modifier -FS is only applicable to split/shared E/M visits. It should not be used for services that do not meet the criteria for split/shared care.