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ACDIS CCDS-O: Outpatient CDI in Hospital Clinics

ACDIS CCDS-O · Work through your exam, one topic at a time.

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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.