Split (or shared) and incident-to visits are two ways a physician and a nonphysician practitioner (NPP) can both contribute to a patient's care while the practice bills under one clinician. They have different rules, and both depend heavily on documentation. Getting the documentation wrong is a common source of denied claims and audit findings, because the record has to show who did what and, for split/shared visits, who performed the substantive portion.
Both involve a physician and an NPP (a nurse practitioner or physician assistant), but they apply in different settings and follow different rules.
| Split/shared visit | Incident-to | |
|---|---|---|
| Setting | Facility settings (for example, hospital) | Office / non-facility setting |
| Who bills | The clinician who performed the substantive portion | The supervising physician |
| New problems | Allowed | Generally not allowed; requires an established plan of care |
| Key documentation | Who performed the substantive portion, plus both clinicians identified | Physician involvement, established plan, and supervision |
Because the rules differ by setting, the first documentation question is always which pathway applies. Applying office incident-to rules to a hospital visit, or vice versa, is a frequent error. These rules matter most in team-based settings; see how documentation fits nurse practitioners and physician assistants and group practices.
A split (or shared) visit is an evaluation and management visit performed jointly by a physician and an NPP in the same group in a facility setting. For Medicare, the clinician who performs the substantive portion bills the visit. Under the CY2024 Medicare Physician Fee Schedule final rule, the substantive portion is defined as more than half of the total time, or a substantive part of the medical decision making (see the CY2024 PFS final rule fact sheet and the CMS article on updates for split or shared E/M visits).
The documentation should:
Because time-based and medical-decision-making pathways are documented differently, this connects directly to E/M coding and documentation.
Incident-to billing lets an NPP's services in the office be billed under the supervising physician when specific conditions are met. The long-standing Medicare requirements generally include:
The documentation should show the physician's prior involvement and the established plan, identify the NPP who provided the service that day, and reflect that supervision requirements were met. Because incident-to rules are detailed and enforced, practices should confirm the current requirements in CMS guidance and their payer policies before relying on them.
Split/shared and incident-to visits determine who gets paid and at what rate, so they are a natural focus for payers and Medicare contractors. In a medical record documentation audit, reviewers check whether the record actually supports the billing pathway used: whether the substantive portion is documented, whether the plan of care and supervision are shown for incident-to, and whether the correct clinician signed. If the documentation does not support the pathway, the claim can be denied or recouped.
An AI scribe does not decide the billing pathway or select codes, but it can make sure the underlying encounter is captured accurately, which is what these rules depend on. DocuMed AI is a HIPAA-compliant AI medical scribe that captures the visit on a mobile device, tablet, or web app and drafts a structured note, so the clinical work of each participant is documented in the moment.
With customizable templates, a group can build note structures that prompt for the elements these visits require, such as who performed the substantive portion or the physician's established plan. The clinician reviews and finalizes every draft, confirms the documentation supports the billing pathway, and signs the note; the biller must be the clinician who performed the substantive portion. DocuMed AI supports coding with E/M, CPT, and ICD-10 suggestions for review, but it does not assign the billing clinician, apply modifiers, or submit claims. See how it works for medical coding support, explore Who We Serve, or request a demo.
Under the CY2024 Medicare Physician Fee Schedule, the substantive portion is more than half of the total time spent, or a substantive part of the medical decision making. The clinician who performs it bills the visit and signs the note, and modifier -FS is reported on the claim.
Generally no. Incident-to requires that the physician has already established the diagnosis and plan of care, so it does not apply to new patients or new problems. Those visits are billed under the clinician who actually performs the service.
Split/shared applies in facility settings and is billed by whoever performed the substantive portion; incident-to applies in the office and is billed under the supervising physician when an established plan and supervision requirements are met.
No. The AI drafts the note from the encounter. The clinician confirms the documentation supports the billing pathway, and the correct clinician signs; billing and modifier decisions stay with the practice.
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DocuMed AI leverages advanced AI Scribe GPT technology to convert ambient sounds and physician-patient conversations into professional medical notes, seamlessly formatted for electronic medical records (EMRs).
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