2023 Gastroenterology Reimbursement and Coding Update (Virtual) | November 2022-CMS Split-Shared CMS Guidelines

Pdf Summary

This document provides an overview of the 2022/2023 CMS Split-Shared Policy and guidelines for Advanced Practice Providers (APPs). APPs are independent healthcare providers with National Provider Identifiers (NPIs), such as Physician Assistants, Nurse Practitioners, and Clinical Psychologists. The Split-Shared Policy refers to medically necessary encounters where both a physician and an APP perform a substantive portion of an Evaluation and Management (E&M) visit with the same patient on the same day. The visit is billed under the practitioner who performed the substantive portion.<br /><br />The CMS 2022 Final Rule refines the policies for split/shared visits by defining them as E&M visits provided in the facility setting by a physician and an APP in the same group. The substantive portion can be history, physical exam, medical decision-making, or more than half of the total time. Modifier FS is required to identify split/shared services, and documentation must identify the two providers, with the provider who performed the substantive portion signing and dating the medical record.<br /><br />For critical care split/shared services, payment is limited to institutional settings, and the billing provider is determined by the performance of the substantive portion of the visit. Time spent by multiple providers in the same group can be aggregated for critical care. The 2023 CMS Fee Schedule proposes to delay the policy for defining the substantive portion as more than half of the total time until 2024.<br /><br />The document also includes clinical examples and a Q&A section addressing billing, documentation, and supervision requirements for split-shared visits. It clarifies that both providers must document their portions of the medical record but only the provider billing for the visit needs to sign it. The provider who performs the substantive portion of the visit is the one billed under. The new CMS policy applies to visits in the facility setting and not office visits.

Asset Subtitle

Kristin Vaughn, CPC, QMC, QMGC, CPMA, ICDCT-CM

Keywords

2022/2023 CMS Split-Shared Policy

Advanced Practice Providers

Physician Assistants

Nurse Practitioners

Clinical Psychologists

Evaluation and Management (E&M) visit

Split-Shared Policy

Modifier FS

Critical care split/shared services

2023 CMS Fee Schedule