Outpatient CDI in Hospital Clinics
Hospital clinics-provider-based outpatient departments and hospital-owned ambulatory clinics-add a facility/professional split to outpatient CDI. The exam tests place of service, incident-to billing, split/shared visits, supervision, and documentation that supports both the professional claim and the facility charge.
Core rules and concepts
- Hospital outpatient departments use POS 19 for off-campus and POS 22 for on-campus. The professional claim reflects where the service occurred; the facility claim captures hospital resources.
- Incident-to services require an established patient, a physician plan of care, direct supervision, and auxiliary personnel. The physician does not have to see the patient, but the documentation must show the plan and supervision.
- Split/shared visits occur when a physician and NPP both see the patient. The substantive portion determines who bills; documentation must identify who performed which element and support the level.
- Clinic notes must show medical necessity, chronic-condition status, medication changes, and the facility resources used, not just the professional history and exam.
Worked example
A patient with heart failure is seen in a cardiology hospital clinic by an NP. The NP documents worsening edema and increases the diuretic. The physician later co-signs without seeing the patient. This is not a split/shared visit because the physician did not perform a substantive portion. If billed incident-to, the record must show the physician’s plan of care and direct supervision. If the physician did examine the patient and adjust therapy, a split/shared visit may be supported, but the note must identify the physician’s contribution. A bare co-signature does not establish a billable physician service.
Traps that cost marks
- Using POS 11 for a hospital clinic encounter.
- Billing incident-to without documented supervision or plan of care.
- Treating a co-signature as a split/shared substantive portion.
- Missing facility documentation for supplies, staff, or clinic resources.
- Unbundling services that are included in the clinic E/M.