Part 2: Split/Shared Billing for Advanced Practice Providers (APPs): A Discussion with Jodi Nayoski and Andrea Ferrari of Pinnacle Healthcare Consulting

Episode Date: June 7, 2023

In this follow-up episode of Stark Integrity, Bob Wade (“Captain Integrity”) continues his discussion with Jodi Nayoski and Andrea Ferrari of Pinnacle Healthcare Consulting, taking a deeper dive into the practical application and compliance risks associated with split/shared billing for Advanced Practice Providers (APPs).

Building on Part 1, Jodi Nayoski and Andrea Ferrari focus on how organizations can operationalize compliance, avoid common pitfalls, and ensure that split/shared billing practices are both accurate and defensible.

Applying the Rules in Practice

A central theme of this episode is the challenge of translating regulatory requirements into day-to-day operations.

Jodi Nayoski and Andrea Ferrari explain that:

• Understanding the rules is only the first step
• Organizations must align workflows with those requirements
• Front-line providers and staff must consistently apply the standards

Without operational alignment, even well-designed policies may fail in practice.

Common Pitfalls in Split/Shared Billing

Jodi Nayoski and Andrea Ferrari highlight several common issues they see in real-world settings.

These include:

• Insufficient physician involvement to meet billing requirements
• Documentation that does not clearly support the billing approach
• Misunderstanding of what constitutes a “substantive portion” of the service

These pitfalls can lead to incorrect billing and increased audit risk, particularly given the scrutiny in this area.

Clarifying “Substantive Portion”

A key area of focus in the episode is the concept of the “substantive portion” of a visit.

Jodi Nayoski and Andrea Ferrari explain that:

• The definition has evolved with regulatory updates
• Organizations must be clear on what qualifies under current guidance
• Documentation must clearly demonstrate the qualifying work performed

Ambiguity in this area is one of the most common sources of compliance exposure.

Documentation as a Defensibility Tool

Consistent with Part 1, Jodi Nayoski and Andrea Ferrari reinforce the importance of documentation—but with a stronger emphasis on defensibility.

They note that:

• Documentation should clearly reflect each provider’s contribution
• Records must support the level of service billed
• Auditors will rely heavily on documentation when evaluating compliance

Strong documentation is not just a requirement—it is a primary defense in the event of an audit.

Training and Education

Another major takeaway from this episode is the importance of ongoing training.

Jodi Nayoski and Andrea Ferrari emphasize that:

• Physicians and APPs must understand their respective roles
• Education should be continuous, not one-time
• Billing and compliance teams must be aligned with clinical staff

Training helps ensure that expectations are understood and consistently applied.

Auditing and Monitoring

Jodi Nayoski and Andrea Ferrari also stress the need for regular auditing and monitoring.

They explain that organizations should:

• Conduct targeted audits of split/shared billing encounters
• Identify patterns of non-compliance early
• Use audit findings to refine processes and education

Proactive monitoring allows organizations to correct issues before they escalate.

Creating a Sustainable Compliance Strategy

A broader theme in Part 2 is the importance of building a sustainable compliance approach.

Jodi Nayoski and Andrea Ferrari note that organizations must:

• Integrate compliance into daily operations
• Maintain flexibility to adapt to regulatory changes
• Continuously improve processes based on feedback and audit results

This long-term approach helps ensure that compliance is not just reactive, but built into the organization’s structure.

Practical Takeaways

The key takeaway from Jodi Nayoski and Andrea Ferrari’s continued insights is that effective split/shared billing requires consistent execution, not just understanding. Organizations should:

• Align workflows with regulatory requirements
• Ensure physician involvement meets defined standards
• Clearly document all provider contributions
• Provide ongoing training and education
• Implement regular auditing and monitoring processes

Final Thoughts

This episode builds on Part 1 by focusing on how to put split/shared billing into practice in a compliant and sustainable way.

Through the practical perspectives of Jodi Nayoski and Andrea Ferrari, it becomes clear that success in this area depends on discipline, clarity, and consistency across clinical, operational, and compliance functions.

Together, Parts 1 and 2 provide a comprehensive roadmap for organizations seeking to navigate the complexities of split/shared billing while minimizing compliance risk.

Click here to listen to this Stark Integrity Podcast Episode:
https://podcasts.apple.com/us/podcast/part-2-split-shared-billing-for-advanced-practice-providers/id1588939373?i=1000615944978&l=fr-FR