‘Split’ Billing for Workers’ Comp

Question: We usually do “split” billing on workers’ compensation patients. We bill the patient’s primary insurance for the medical condition that is not work related - say, hypertension or diabetes - and then bill the same E&M code on the same day for the same amount to the workers’ comp insurance with the work-related diagnosis.

We do two complete visit notes. Is that right?

Answer: It is OK to bill two separate insurance companies, one for workers’ comp issues and one for nonworkers’ comp issues.

It may not be safe to assume that each service merits the same E&M code. Code based on work done.

A single note to document two services is fine. Of course, both services need to be supported. That is, if an auditor from either carrier were to review the record, each should be able to pull out her company’s documentation requirements.

In other words, a key issue here is whether the patient actually is being seen for hypertension or diabetes during the visit and there is a legitimate, related, medically necessary review of systems and medical decision making for that problem.