Question

I am a physician practice manager and responsible for monitoring my group’s productivity. I understand that Medicare publishes a list of relative values by CPT codes. Does this list also have times associated with the CPT codes?

Answer

Yes, CMS publishes all CPT and HCPCS active codes with relative values on a quarterly and annual basis. Those values are broken into Physician work, Practice Expense and Professional Liability Insurance (Malpractice). These RVU files can be found here. As an example, RVU16C would be the RVU file for 2016 and C means that it is the third update, likely for July 2016. Those downloadable zip files have lots of information. Look for the file that starts with PPRRVU. This is the file that will have the RVUs and the conversion factor. Unfortunately, CMS does not post the RVU and the times in the same files, but they do post them. To locate the times for each CPT code, go to the PFS Federal Regulation Notices, where proposed and final rules are posted each year. Select the final rule or the most current rule if there are corrections or updates for the year of interest. If you were obtaining the most current as of March 26, 2016 you would select the following URL, updated March 2016. Here you will find again many downloadable files, however for times you would select the file that says, FINAL RULE WORK TIME in the title. That will contain the breakdown and total time by CPT code for your information. If you have questions, you may always contact ATS staff at coding@thoracic.org

Question

I work in a large community based pulmonary critical care group practice. We recently acquired a group of NPPs (Non Physician Providers) who work exclusively in the ICU and were previous employees of the hospital. They will now be covering nights in the ICU and working with our physicians during the day. Can they bill critical care? What about procedures? Can they do shared/split billing with our physicians?

Answer

NPPs are able to bill independently for critical care services (and be reimbursed at 85 percent). A physician need not be present physically for this to occur. So, your group can and should bill for critical care services performed by the NPPs and the same documentation rules apply as for any provider. Additionally, cosignature and supervision are not required. The NPPs may perform procedures and bill for them as well, acknowledging hospital credentialing rules. Even if a physician is needed to supervise the procedure, the NPP bills for the procedure. Shared/split billing is recognized by CMS and may be done on specific E&M services. Shared/split billing is however NOT allowed with critical care (99291-99292).