Addressing the Physician Fee Schedule – Final Rule on Split/Shared Billing

Struggling to understand the recent changes on split/shared billing and how it will affect physician and advanced practice provider workflow?


The 2022 Physician Fee Schedule (PFS) Final Rule included significant adjustments to split/shared visit policies in order to:

  • Better reflect clinical practice
  • Recognize APPs as members of the care team
  • Reduce duplication of services (create access)
  • Clarify payment conditions

Organizations must understand the timeline of past and upcoming changes in order to properly address and plan for the pending modifications:

Pre-2022

  • A split/shared visit is an encounter performed in the hospital inpatient/hospital outpatient setting that is shared between a physician and an APP from the same group practice. Must include a medically necessary contribution to the evaluation and management (e.g., history, physical or medical decision-making) by the physician and a face-to-face encounter by the physician (excludes critical care codes).

2022 and 2023

  • Modifier (-FS) to be included in all shared visit encounters
  • Critical care services now billed as split/shared visits
  • Can be reported using time-based or historical E&M methodology

Starting January 1, 2024

  • Shared visits are to be billed via the time-based methodology
  • “The practitioner who provides the substantive portion of the visit (more than one-half of the total time spent) will bill for the visit”
  • Accounting for time consists of various elements

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