The Health Insurance Portability and Accountability Act (HIPAA) requires that UConn Health have appropriate safeguards in place to protect the privacy of protected health information (PHI). Here are some helpful hints for protecting PHI:

• Don’t leave paper records that contain PHI unattended. Use a shredder bin to dispose of paper PHI.
• Physically secure electronic devices that contain ePHI when not in use to prevent unauthorized access.
• Don’t discuss PHI in high traffic areas, such as the cafeteria, elevators, and hallways.
• The same HIPAA rules apply when you are working at home as they do in the office. Make sure PHI is not visible or heard by others in your home.

If you have any questions, need guidance, or have a privacy concern, please contact The Office of Healthcare Compliance & Privacy.

 

Effective January 1, Medicare split/shared visit guidelines were revised. Medicare defines a split/shared visit as an evaluation and management visit in a facility setting performed by a physician and a non-physician practitioner (NPP) who are in the same group (tax id number). Each practitioner performs components of the visit but only one practitioner bills Medicare for the service.

Below is a summary of key changes for 2022:

• Split/shared may now be utilized for:
  • new patient visits
  • initial visits
  • critical care services
  • prolonged services
• A Split/shared visit must be billed by the provider who performs the substantive portion of the visit. The substantive provider is defined as:
  • Non-Critical Care: the provider who performs one of the three key components in its entirety (history, exam, medical decision making) or who provides more than half of the total visit time
  • Critical Care: the provider who provides more than half of the total visit time

Because Medicare has different payment rates for physicians and NPPs, it is important to correctly identify and bill under the substantive provider. Otherwise, underpayments or overpayments will occur.

• The substantive portion can be comprised of time that is with or without a patient face-to-face encounter.
• One of the providers is required to have face-to-face time with the patient but it does not have to be the provider who bills Medicare.
• Medicare claims for split/shared visits are now required to have modifier FS. This will allow Medicare to easily identify, monitor and audit provider split/shared visit utilization.

If you have questions or would like additional split/shared guidance, please contact the Office of Healthcare Compliance and Privacy.