Awareness : Frequently Asked Questions

What is meant by merged records?

Question: In regard to E/M guidelines pertaining to transfer of a patient, what is meant by the term “merged records?”

Answer: The CMS Internet-Only Manual guidelines regarding physicians billing for patient transfer are as follows:

  • Physicians may bill both the hospital discharge management code and an initial hospital care code when the discharge and admission do not occur on the same day if the transfer is between:
  • Different hospitals;
  • Different facilities under common ownership which do not have merged records; or
  • Between the acute care hospital and a Prospective Payment System (PPS) exempt unit within the same hospital when there are no merged records
  • In all other transfer circumstances, the physician should bill only the appropriate level of subsequent hospital care for the date of transfer.

In the above summary, “merged records” would indicate the tax identification and/or the provider identification numbers being used are the same, and thus, the entity is the same. In that case, the physician should bill only the appropriate level of subsequent hospital care for the date of transfer.

Source: CMS Internet-only Manual (IOM) Publication 100-04 Medicare Claims Processing Manual, Chapter 12, Section 30.6.9.1E