Shared Services Performed by Physicians and APPs: A Discussion with Amy Noecker and Zachary Hartsell from SullivanCotter

Episode Date: June 29, 2022

In this episode of Stark Integrity, host Bob Wade (“Captain Integrity”) is joined by Amy Noecker, APP Workforce Practice Leader, and Zachary Hartsell, Principal, both from SullivanCotter, to discuss shared services performed by physicians and advanced practice providers (APPs) under the Stark Law.

This episode dives into the evolving regulatory landscape and operational challenges tied to split/shared billing and care team collaboration.

A Changing Landscape for Shared Services

A central theme of this discussion is that recent changes to reimbursement rules—particularly under the Physician Fee Schedule—are driving significant workflow changes.

As Amy and Zach explain:

• Organizations must reassess how services are delivered and documented
• Billing methodologies for shared visits are evolving
• Compliance expectations are becoming more complex

These changes are forcing healthcare organizations to rethink both care delivery models and compensation structures.

Understanding Split/Shared Billing

At its core, shared services involve both a physician and an APP contributing to a patient’s care.

This episode highlights:

• How split/shared billing works
• The importance of identifying which provider “owns” the encounter
• The operational complexity of allocating credit between providers

The shift toward time-based methodologies is especially important, as it changes how services are attributed and reimbursed.

Evaluating Care Team Composition

Amy and Zach emphasize the need to carefully evaluate care team roles and responsibilities.

Organizations should:

• Clearly define who performs which services
• Align provider roles with documentation requirements
• Ensure responsibilities are consistent with how services are billed

Without this alignment, organizations risk inconsistencies that can create compliance exposure.

Impact on Compensation Models

One of the most important implications discussed in this episode is the impact on physician and APP compensation.

Changes in shared services billing may require:

• Adjustments to productivity metrics (e.g., wRVUs)
• Reallocation of credit between physicians and APPs
• Reevaluation of overall compensation structures

Organizations must ensure that compensation remains:

• Fair market value
• Commercially reasonable
• Not tied to the volume or value of referrals

These changes can significantly affect both financial sustainability and compliance.

The Shift to Time-Based Methodology

A major focus of the episode is the move toward time-based billing for shared services.

This shift requires:

• Accurate tracking of time spent by each provider
• Clear documentation of contributions
• Consistency between documentation and billing practices

Time-based methodologies introduce new complexity, especially when multiple providers are involved in a single encounter.

Key Compliance Risks

The discussion also highlights areas where organizations may encounter risk:

• Inconsistent documentation between physicians and APPs
• Misalignment between billing and actual services performed
• Improper allocation of productivity credit
• Failure to update compensation models to reflect new rules

These risks can lead to Stark Law and False Claims Act exposure if not properly managed.

Practical Takeaways

The central takeaway from this episode is that shared services require careful coordination between clinical operations, billing, and compliance. Healthcare organizations should:

• Reevaluate split/shared billing practices
• Clearly define provider roles and responsibilities
• Align compensation with updated billing methodologies
• Implement strong documentation and time-tracking processes

Final Thoughts

With insights from Amy Noecker and Zachary Hartsell, this episode highlights how regulatory changes are reshaping the way physicians and APPs collaborate.

Shared services are no longer just an operational issue—they are a compliance and compensation challenge. Organizations that proactively adapt to these changes will be better positioned to maintain compliance, optimize care delivery, and support sustainable provider compensation models.

Click here to listen to this Stark Integrity Podcast Episode:
https://podcasts.apple.com/us/podcast/shared-services-performed-by-physicians-and-apps/id1588939373?i=1000567336562&l=fr-FR