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
