Hello, on behalf of AOFAS, I want to welcome you to the fourth session of Crack the Code Practice Management and Coding Course Series. Today's session is session four, PA and NP Billing Strategies for both the office and hospital. Today's presentation will be given by Jennifer Cabrera and Jennifer Bell. You can find their full biographies and disclosures in the program document posted in the chat box and in the on-demand education center. The series is funded from the Orthopedic Foot and Ankle Foundation, supported by grants from Paragon 28. I'd like to run through a few housekeeping items before we kick off the presentation. For technical difficulties, please try closing your browser and logging back in the same way you did the first time. Registered attendees may earn .45 hours of AMA, PRA, Category 1 CME credit by completing an evaluation and CME claim form at the end of the full series. Tomorrow, you will receive an email with a link to evaluate this specific session, and then at the end of the seven broadcasts, you will be able to evaluate and claim CME for the full course. This webinar is being recorded and will be available for on-demand viewing in the on-demand education center as a module within the course listing. It will be available in approximately 24 hours, and the recording will be available for one year. We encourage you to ask questions during the presentation. To send your question to the faculty, click on the Q&A tab on your navigation bar. If we cannot get to your question during the live broadcast, the faculty will reach out to you to respond. I will now turn the program over to Jennifer Cabrera. Thank you. Thank you and welcome. Thank you for joining myself and Jen Bell for a lesson on PA and NP billing for Medicare. We'll get this going for you. Jen Bell and I both work with Karen Zupko and Associates. You can see both of us with the two ladies in glasses and we welcome you for joining us today. This is Jennifer Bell and I am Jennifer Cabrera. All right, today we're gonna be talking about three ways to bill for your PAs and NPs. This is just a brief review that we'll go over. Essentially, we have three different options. We can bill incident to billing, as you see this on the left-hand side of our screen, where as we note, there are some restrictions here and higher reimbursement. And this is versus our right side of the screen where we're doing direct billing, which has fewer restrictions and lower reimbursement. And then in the middle, which we'll be touching on later in the presentation is our split shared billing. So this is where some changes have occurred in the last couple of years and moving into 2023 and 2024, where reimbursement depends on the provider and now determined by what's called the substantive portion criteria. And we'll go into this in quite a bit more detail shortly. All right, so some just key facts about incident to and split shared billing. You know, where do these terms come from and what do they exactly mean? So incident to and split shared billing are terms that were actually developed by Medicare. And the purpose is how to report for services for our non-physician providers and ancillary staff. Now, AMA, just so you know, does have their own term split shared and noted in E&M 2021, but that is different than the CMS guidelines or Medicare guidelines for split shared. And that's what we'll be focusing on today. People tend to ask us why we follow CMS guidelines and truly we always say follow Medicare because they put their rules in writing and they follow their rules. So we're gonna follow the split shared reporting rules of CMS. All right, and just of note with CMS billing, remember we're speaking about Medicare payers, essentially commercial insurances may not necessarily have the same guidelines for incident to or split shared billing. Some do not recognize these terms as well. So you really wanna make sure that you and your staff do your research on these commercial payers and understand what the guidelines are for specific payers. So for example, some payers may have their own modifier that they recognize that is different than the CMS guidelines. And an example of this is there is a modifier SA that is used to distinguish a nurse practitioner who is rendering service in collaboration with the physician. This modifier is not used by Medicare. So again, just make sure you really do your research so you have an understanding of what the requirements are per payer. All right, so just to go in a little bit more detail here on these terms. So we talk about NPPs, our non-physician practitioners and then our APPs which will be most of the focus for today which is our advanced practice providers. Now you can use NPPs interchangeably to discuss your PAs or describe, excuse me, your PAs, your nurse practitioners. But in addition to that, NPPs is all encompassing for other positions that are not credentialed by Medicare. So your registered nurse first assist, your LPNs, your scrub techs, ortho techs, athletic trainers. And as you can see by this diagram on this slide is that incident two can apply both for your NPPs and your APPs versus direct and split shared which only applies to your physician assistants, nurse practitioners and your clinical nurse specialists. So it's limited to those that are credentialed by Medicare. All right, so as we go a little bit more into incident two billing, remember we talked about these details a little bit previously where it's defined by a service that's provided by a non-physician provider or auxiliary personnel but is billed by the physician using the physician's NPI number, okay? Now the benefit of this is that it's reimbursed at 100% of the Medicare physician fee schedule. And then the place of service for incident two billing is only in place of service 11 which would be an office setting. So you're not going to bill incident two in your academic settings, hospital-based practices or provider-based practices. Now there's a certain subset of criteria to qualify for incident two billing that need to be established when you're going to bill incident two. And we'll cover this in detail and then go over some scenarios so you can have a better understanding of what that entails. So in order to bill incident two, it needs to be an established patient with an established problem. So initial evaluations and treatment plans are initiated by the physician. And the key to this is that a plan of care has already been established by the physician. So again, established patients with established plans of care is the first criteria needed to be able to qualify to bill incident two. In addition to that, as with anything, member NPPs, whether it's your PA or NPP, excuse me, your PA or nurse practitioners, we do have a scope of practice that is variable per state. And so obviously for understanding what services that are provided within your state and what is allowable under that state scope of practice for your advanced practice providers. In addition, the service must be furnished under the physician's direct personal supervision, meaning that the billing physician who will bill under incident two must be present in the office suite and immediately available to provide assistance. So, and then again, the billing physician can be a member of the group who is in the office suite other than physician who set the original plan of care. So remember, always going back to criteria number one, this is an established patient with an established problem where a plan of care has already been initiated by the physician. In addition to that, so there does need to be a legal cost relationship between the provider and the NPP. So whether they're an employee, independent contractor, or an entity that employs or contracts that the incident two billing is furnished by that person who qualifies as an employee of the physician. And lastly, again, here in number five, incident two, reporting is only allowed in place of service 11, your office setting, as opposed to not being permitted in provider-based clinics, inpatient services, or ER services. So you'll only see this in place of service 11. Now, often because of guidelines based on the state that you're in and also just the regulations over PAs and NPs, we get often the question is, is the supervising physician required to sign the note by the PA or NP when services are reported incident two? And currently the Medicare guidelines do not require this. So Medicare does not include a requirement for a note signature, but again, we always defer back to the state regulations, which will be variable for PAs and NPs. So making sure you always stay up to date on what those criteria are for your own state or what those requirements are. So a little bit about direct billing. Now that we've reviewed incident two billing is the alternate end of that spectrum is our direct billing. Now, direct billing, again, as we noted on our very first slide is that this has lower restrictions or less restrictions, if you will, but also has a lower reimbursement attached to it. So when we define direct billing, we are saying that our APP is rendering the service and they're billing under their own, his or her own NPI. Now, keep in mind first assistance in surgery by a PA or an NP is always under direct billing. So there is no incident two or split shared billing when it comes to services as a first assist in surgery, for example, or any procedure assistance. Now, again, the financial impact of this is that when you do direct billing, your APP is reimbursed at 85% of the Medicare fee schedule or what's allowable. So there is a reduction in services there as well, but the caveat is that direct billing can be utilized in all settings. So office, place of service 11, our outpatient hospitals, provider-based clinics, inpatient hospitals, and the ER. So it gives you quite a bit more availability to use direct billing as opposed to incident two that is only in place of service 11. Some key facts about direct billing. Remember, there are no restrictions about the type of patient being seen. This is in direct correlation with our incident two where it has to be established patient with an established plan of care. Whereas direct billing, there are no restrictions. So you can have a new or established patient visit and there are no CMS requirements for physician supervision. Again, other than what's required by your licensure or your state regulations. As always, we want our APPs practicing within their own scope of practice. And I think that goes without saying. And lastly, direct billing again is allowed in all places of service. So place of service 11, provider-based clinics, inpatient services. Now, also again, remember procedures can be direct billed if they're within the state scope of practice as well. An example of this would be your APP providing like an injection in the office. Excuse me, I'm a little under the weather. So I apologize, I may cough just for a moment. My apologies. So let's take some examples and take a look at some of these examples on incident two versus direct billing. So how is this scenario reported to Medicare? We have a PA who's employed by Dr. Ortho and sees a new patient with bilateral shoulder pain in the office. Now, Dr. Ortho is in the office, but does not see the patient. So I always break this down to the major criteria for incident two billing. So essentially one, we're gonna look at is the supervision requirement been met in this scenario? And it has been, Dr. Ortho is in the office. And remember the requirement is not that they see the patient, but that they are present in the office suite. Okay, the second part of our criteria is has the plan been established? And again, remember with incident two billing, we're looking at an established patient with established plan of care. So we're looking at a patient with an established plan of care. An established patient with established plan of care. So in this scenario with a new patient, we would not qualify for our incident two billing. And this would be billed under direct in a place of service 11. And again, place of service 19 and 22, we are not able to bill incident two in those places of service. Therefore, this would also fall under direct billing in those locations. All right, our next scenario, we have a PA employed by Dr. Ortho who sees an established patient with right elbow pain for follow-up in the office. The patient was originally seen by the PA and services reported direct under the PA provider number. Now Dr. Ortho is in the office, but does not see the patient. Dr. Ortho reviews and signs the note. So again, back to our original criteria as the supervision requirement that met and it has been in this scenario, Dr. Ortho is in the office and then has a plan of care been established in this patient? So again, this is established patient with the right elbow pain. Patient however, was originally seen by the PA. So the plan of care does need to be established by a physician as opposed to the PA or NP. Therefore for this scenario in place of service 11, this would be billed under direct as opposed to incident two. Again, incident two billing is only permitted in place of service 11. So for our outpatient hospitals or our place of service 19 or 22, this again would fall under direct billing. All right, moving on to our next scenario. We've got a PA employed by Dr. Ortho who sees an established patient with right wrist pain for followup in the office. The patient was originally evaluated by Dr. Ortho for right wrist pain and a plan of care was documented. The PA is carrying out the plan of care set by Dr. Ortho. Dr. Ortho is in the office, but does not see the patient. So let's go through our criteria here. Has our supervision requirement been met in this scenario? And it has been. Dr. Ortho is in the office. And do we have a plan of care established for this patient? So we've got an established patient, right wrist pain was originally evaluated by Dr. Ortho for the same right wrist pain and a plan of care was documented. Therefore this scenario would qualify under our incident two billing for place of service 11. Again, as a requirement, direct billing is our only option in place of service 19 or 22. So we've not billed incident two in these locations. All right, a few more scenarios and then we can move into our split shared. Okay, so we've got a PA employed by Dr. Ortho who sees an established patient with left knee pain for followup in the office. The patient was originally evaluated by Dr. Ortho for left knee pain and a plan of care was documented. The PA is carrying out the plan of care set by Dr. Ortho and Dr. Ortho is in the OR. So again, always coming back to our incident two criteria, has the supervision requirement been met? And in this case, it is not as Dr. Ortho is in the OR and for incident two billing, the doctor does need to be in the office suite. Now a plan of care has been established and is being carried out by the PA, but because of that additional requirement that the supervision, excuse me, that the doctor must be available in the office suite, this scenario would qualify for direct billing in place of service 11, and again, direct billing in a place of service of 19 or 22 as incident two does not qualify in those areas. All right. Scenario number five, we have a PA employed by Dr. Ortho who sees an established patient with knee pain for follow-up in the office. The patient was originally evaluated by Dr. Ortho for knee pain and a plan of care was documented. The PA is carrying out the plan of care set by Dr. Ortho. Dr. Ortho is in the OR, but his partner Dr. Sports is in the office. So again, has our supervision requirement been met in this scenario? And yes, it has been, but not by Dr. Ortho, by Dr. Sports. So Dr. Sports is in the office. And is this established patient with an established plan of care? So our answer here would be that yes, it is incident two, because we do have an established plan of care, an established patient, and there is a doctor in the office, but it's Dr. Sports. But this would be incident two billing to Dr. Sports as opposed to Dr. Ortho, because it has to be, it can be a doctor from the same group, but one does have to be in the office suite. Now, in a cost-sharing relationship, one of the questions we get is, for example, in this scenario, if Dr. Ortho is the person who employs this PA for this scenario and says, well, I prefer to have this revenue aligned to myself as opposed to Dr. Sports, then you could do that. However, then it would go under direct billing. So our green box here. So if Dr. Ortho decides they want the revenue of this PA visit aligned to them, it would be considered direct billing, and they would accept that lower reimbursement as opposed to the alignment to Dr. Sports. And again, in places service 19 or 22, our only option for this is direct. Now, just a documentation recommendation that I would say for our APPs is that you always wanna reference the previous visit in your note. Now, this will not necessarily be all-encompassing if you were ever audited, but I definitely think that it will help if you document, for example, saying, Mrs. Smith is returning to the office today for evaluation of her left knee. Patient was previously seen by Dr. Ortho and a plan of care was established for the patient to return to the office for a cortisone injection. So just putting that documentation in there that the patient was originally seen by the physician and a plan of care was established, I think was good documentation practice, okay? All right, so now let's get into the crux of what we're talking about today where the changes have taken place in 2022, and that would be our split-shared billing, okay? So we're gonna go, in your handout, there's a nice table for you to look at where there's any blanks on the left side is because there's no previous policy regarding this area of split-shared billing. And we'll just do a then versus now comparison so you understand where the changes have taken place. So prior to 2022, the physician and the PANP must each provide a face-to-face service with the patient on the same day and document their respective findings. The service may be billed by the physician. Now, beginning in 2022, the PA and NP must each provide a portion of the service with the patient on the same day and document their respective work. But now it's modified and created this new term where the service must be billed by the provider who performs what they call the substantive portion of the visit. And we'll discuss that in more detail on how you define the substantive portion. Now, mind you, services may include both face-to-face and non-face-to-face activities as defined by CPT. Remember, a face-to-face encounter is not required for the billing provider if the other provider performed that face-to-face service. So remember, they don't both have to provide a face-to-face. Only one is required in the new changes since 2022. And then the individual who perform what's considered the substantive portion must sign and date the medical record, okay? So continuing on here, so prior to 2022, if a split-shared visit is performed in the office or clinical setting, incident two criteria will be met. Since 2022, they remove that office setting. Remember, we talked about split-shared is in your places, excuse me, your additional places of services like the facility setting where now your incident two is for the office setting place of service 11, okay? And now split-shared rules apply to E&M services for going jointly by the physician and the PANP in the same group, again, in the facility setting. So you're gonna see our split-shared in inpatient hospital, outpatient hospital, observation settings, emergency departments, but if it's place of service 11, we're gonna refer back to that incident two criteria that we just discussed. Again, always line number six here, we want our APPs always working within their state scope of practice, and there's been no change with that. Something I will note is that the scope of practice definitely did change during COVID years, so make sure you stay up to date because some of the restrictions that were lifted during those last couple of years have remained in place while some have returned to their pre-COVID restrictions and some have had their guidelines changed completely. So you definitely wanna stay up to date on that. Again, prior to 22, there was really no modifier that existed to designate a split-shared visit where historically there was no method, where now we have a new modifier in 2022, which is our modifier FS, and that would be designated on the provider who actually performs the substantial portion of the visit. Well, we have this cost relationship in item number eight, you've got your PA or NP was employed under the same group or physician practice. Now CMS has changed the guidelines slightly or the wording of it so much where it says CMS is saying the physician and the PA NP must be in the same group, but they don't really define what group means at this time. So we still believe there is that cost-sharing relationship between the provider and the APP. And again, as we noted earlier, member procedures cannot be reported using split-shared billing and there's no change to that. Those are always considered direct, for example, in a first assist situation for surgery. All right, so additional information about split-shared, remember this is gonna change in the upcoming years. It was anticipated to change in 2023, but has now changed to 2024. And there's just a mismatch essentially or how we determine it is going to be narrowed slightly since there's been all these changes in criteria with our E&M changing to MDM versus time in the office. And then in the hospital setting, we're still using H&P exam and other parts of the visit to determine our billing units. So we'll go over that and we'll see those changes coming probably next year. All right, so determining the substantial portion of the visit is determined in two different methods. So we have our first option here where it's pretty straightforward where you're reporting the substantial portion based on provider who performed greater than 50% of the total time of the visit. So time criteria are consistent with those outlined in 2021. There is a breakdown of how that time criteria is listed in your handout. And it's right here where you have the time spent preparing to see the patient, obtaining and reviewing, obtaining, excuse me, separately obtained history, the medically appropriate exam, counseling, again, ordering medications, tests, or procedures. And we don't double count the time performing these procedures. Referring and communicating with other healthcare professionals regarding this care when not otherwise reported, documenting our clinical information. Again, independently interpreting results not separately reported as well. So that's our option number one. Our option number two is when you report the substantial portion based upon the provider who performs either the history or exam or medical decision-making in its entirety. So again, let me repeat that. It's reporting based on the provider who performs either the history or exam or medical decision-making portion of the note in its entirety, okay? We're gonna skip ahead a little bit here to get back to this slide. So we find that more often than not, people are using, excuse me, using option number two because we've seen historically that, you know, the physician is not spending greater than 50% of the time at the visit. Now that may vary based on your practice and of course your practice setting. But now that they've created this criteria where you've got only one of the three, whether it's the history or exam or medical decision-making that is the requirement, option two is very feasible for physicians. Okay, now this does present a little bit of a conundrum if you will, because there's kind of two different thought processes or criteria, if you will, for choosing. So rules for choosing who bills the service is based on a substantial portion. Remember using option one, which is greater than 50% of the time at a visit or option two, the person who, excuse me, completed the history or exam or the medical decision-making portion in their entirety. And then the level of service is still based on our CPT definition set in 2021, which is medical decision-making or time. So there's a little bit of a mismatch there and we'll show you that. We're hoping that we'll get some more clarity in the next year about this, because they're going to, you know, cut down these guidelines a little bit more. On this slide, we're going to start on the far right here and go with our ED and department services. As you can see, criteria for choosing the level service is still based on history exam and our medical decision-making. Whereas in our next column, we have our outpatient hospital, emergency room hospital setting again, where you have history exam or original guidelines versus our time. And then here's where we're finding our split criteria, our little conundrum that we talked about, where you've got your original rules for determining your level of service, which is total time or MDM based on the new 2021 criteria versus our substantial portion on who actually gets the credit for the substantial portion, which is our option one or option two at the bottom. And again, lastly, our split shared, excuse me, our office service 11 member split shared rules do not apply here. So you would always go back to your incident two billing in these two places of service. Okay. All right. So what's ahead for 2024 and beyond, CMS has indicated that the only method used to determine that substantial portion of the split shared visit will end up going to our greater than 50% of total time. So stay tuned for those. We'll see that in the upcoming year as a possible change. Again, this change was supposed to take place in 2023 and now has been pushed to 2024. So we will keep you abreast of those changes. So let's review some split shared exercises here. We've got a PA employed by Dr. Ortho who sees a new patient with knee pain in a provider based office. Now the PA sees the patient first and performs and documents history exam and medical decision-making. The PA asked the physician to review the imaging and she documents her independent interpretations of the x-rays. Now Dr. Ortho reviews the history exam and medical decision-making the PA documented. Dr. Ortho and the PA meet with the patient together to present the recommendations. Dr. Ortho signs the note and the PA spent a total of 10 minutes independently. Dr. Ortho spent 15 minutes alone or jointly with the PA. So now we're going to establish if this qualifies for split shared and if so, by who, okay? So for this scenario, we think this does meet the requirements for a split shared visit and this would be split shared by Dr. Ortho and we'll discuss why that is, okay? So how was that substantial requirement met to why Dr. Ortho gets the credit for that substantial portion? And this would be based on total time. So remember grading them 50% of the time was spent by Dr. Ortho of the 25 minute visit. Therefore, Dr. Ortho would have completed the substantial portion requirement. All right, and will a modifier be required for this visit? The answer here would also be yes. Excuse me for one moment. My apologies. Couldn't have picked a better time to come down with the cold. In scenario one, will a modifier be required for this visit? And the answer is yes, modifier FS. Excuse me. All right, continuing on. Now, what if the scenario occurred in a place of service 11? Are we able to bill a split shared visit? And the answer here is no. Remember, our split shared visits are not applicable to place of service 11. The code selection would only be considered incident two criteria for this place of service. All right, so scenario number two. We've got a PA employed by Dr. Huerto who sees a patient in the emergency department for a suspected hip fracture. He spends 30 minutes performing and documenting history, exam and medical decision-making in the ED and additional 10 minutes on the inpatient floor once the patient is admitted. Now, Dr. Huerto sees the patient later the same day and performs her own assessment and documentation of the MDM criteria for an initial hospital care service. He signs and dates the note and his encounter took 15 minutes. All right, so this does meet our split share criteria and who would we addend this to? We would attribute the split share criteria to our Dr. Huerto again in this scenario. So how was this substantial requirement met? Remember, we've got our two options. So greater than 50% of the total time or did one of the providers perform either the history, the exam or medical decision-making in their entirety? And in this scenario, Dr. Huerto did perform and document either of the history, exam or MDM in its entirety. Therefore, they would be awarded this split share. All right, now would the answer change if the physician did not have a face-to-face visit with the patient on the same date but did perform the medical decision-making? And the answer here would be no because the PA did provide a face-to-face encounter. So remember, in 2022, the requirements change so it's no longer required that both providers deliver a face-to-face service as long as one does. And again, would we require a modifier for this visit? Yes, we would and we would always put the modifier on the provider who is performing the substantial portion. Now, lastly, would the answer change if the physician did not perform his evaluation into next calendar day? And yes, that would change the scenario is that would not meet the split share requirement that both services are performed on the same day. So in that case, the PA's evaluation will be reported under direct billing as opposed to split share. Perfect, all right. So a little bit of AMA guidance on split share criteria is remember this will affect your codes for 99202 through 99215, our new and established office or other outpatient services. And essentially this is coming down to counting time and that we cannot duplicate or count overlapping time, if you will. So CMS specified that a shared or split visit is defined as a visit in which a physician and other qualified healthcare professionals jointly provide face-to-face and non-face-to-face work related to the visit. Now, when time is being used to select the appropriate level of services for which time-based reporting is allowed, time personally spent by the physician and the QHP assessing and managing the patient on the date of encounter is summed to define the total time. So only distinct time should be summed for split or shared visits, not overlapping time. And we'll show you an example of this here. So we have a patient with osteoarthritis of the knee previously diagnosed by your group's physician returns to the office for an established visit with the nurse practitioner. The physician's previous plan of care indicated that the patient may return and be seen by the NP for a non-steroidal prescription and that the patient continued to be symptomatic using over-the-counter medication. Now, during the visit, the patient asked to have the physician join the encounter to answer several questions. No new data was ordered or reviewed at this visit. No new plan of care was set by the NP or the physician. So here we have the NP spent 20 minutes alone performing the history exam and medical decision-making. The physician did join the visit for an additional five minutes of counseling, time where the NP was also present. So when we're looking at total time here, total time would be considered 25 minutes. So 20 minutes with the NP and five minutes with the NP and the physician together. So we're not counting double time. So it would not be 30 minutes, it would be the 25 minutes. And now remember, if you're billing using time, this scenario would support a 20 to 29 minute code of a level three versus a level four for 30 to 39 minutes, okay? So remember, don't count overlapping time, only total time summed, all right? And that's all we have for you today regarding our incident two, our direct billing and our split shared billing. On behalf of Jennifer Bell and myself and Karen Zepko and associates, we thank you and we will open up for any questions if we have any at this time. Thank you so much. All right, if you have questions, just submit them under the Q&A section and we'll be glad to answer those for you. Looks like we have a couple here, Jen. Yes, the first one is since I'm an NP, not a PA, can I bill for incident two without a physician in the office suite? It would be considered direct billing at that point in order to bill under incident two, regardless of the restrictions that NPs don't require technically supervision, whereas PAs do. In order to bill incident two, that criteria does need to be met. So yes, you would still require a physician in the office suite. Otherwise it would just be considered direct billing under the NP provider. Okay, and second question here, it looks like we have three questions so far. If the doctor sees the patient and the PA comes in to execute the plan of care, would this be incident two in the office? This would actually be considered, it's a great question. When the physician is seeing the patient first and establishing a plan of care, say they come in, the patient has arthritis, and they ask the PA to then carry out an injection, that would just be going as direct bill under the physician themselves, as opposed to incident two. Okay, and that actually leads into the next question. It's a good segue. What's the reimbursement difference for incident two direct and split shared? So you wanna comment on that? What's the difference? Yeah, so incident two billing, if you want, you can go to your first slide in our handout. Incident two billing, what we say has more restrictions but higher reimbursement, where direct billing, fewer restrictions, lower reimbursement. So when it's incident two billing, it's actually reimbursed at 100% of the Medicare physician fee schedule. So that's the advantage under incident two billing because it's being billed using the physician's fee. So it's actually being paid for incident two billing because it's being billed using the physician's NPI or provider information versus direct billing, you will have that 15% reduction in services. So you'll be getting 85% of the Medicare allowable fee schedule. And then Jen Bell, can you touch on split shared? If it's, I believe it's still 100%. Yeah, the same, yeah, exactly. The same holds true if this shared split visit is billed under the physician, then it would be at 100% of the physician fee schedule. If it winds up that the substantive portion was performed by the NP or the PA, then it would be at 85% of the fee schedule. Perfect, thank you. And let's see, I don't see any more questions. All right. All right. Well, perfect, okay. Well, I think we're ending just a little bit early. If you have any additional questions, please let us know. We'll be happy to answer at any point. And thank you so much for spending some time with us today. Have a great day.

billing strategies

physician assistants

nurse practitioners

incident-to billing

direct billing

split-shared billing

reimbursement