Definition of Split/shared services
E/M services performed jointly by a physician and non-physician practitioner in a facility setting (outpatient department, inpatient, emergency department, skilled nursing facility) Prior to 2021, shared services were a Medicare concept For Medicare, payment differential for services billed by physicians and NPPs.
In 2021, the AMA added the concept of shared services between a physician and qualified health care professional (QHP) (CMS uses the term non-physician practitioner (NPP))
Both QHP and NPP mean someone who has E/M in their scope of practice. Allows for E/M services to be jointly performed by a physician an NPP.
In May 2021, CMS removed instructions for shared services, critical care and nursing home services from the Medicare Claims Processing Manual, said they would address it in rulemaking
Split/shared in 2022 per Final Rule:
• Allowed: in facility settings inpatient, outpatient including OBS, ED
• Allowed: in nursing facility for visits not mandated to be done by a physician
• Allowed: for critical care
• Removed: allowed in office setting if met incident-to requirements
Read also: The new CPT code changes for 2022
CMS’s 2022 shared or split services policy
- Shared or split services are Evaluation and Management (E/M) services performed jointly between a physician and a non-physician practitioner (NPP), in the same group, in a facility setting.
- Services may include both face-to-face and non-face-to-face activities, as defined by CPT.
- Services billed using the physician’s NPI are paid at a higher rate than those billed by a non-physician practitioner.
- CMS states that the service should be reported by the clinician who performs a substantive portion of the visit.
- New HCPCS modifier for 1-1-2022 FS- Split (or shared) Evaluation and Management service
Read also: When to use 25 and 27 modifier with E/M codes
Substantive portion
CMS believes E/M services performed split shared should be reported by the clinician who does a “substantive portion” of the visit
• In 2023, this will be based on time
• In 2022, a transitional year, may be based on time or key components Also allowing prolonged care to be reported as split/shared
• New modifier required: CMS will be able to identify split/shared services
FS: Split (or shared) evaluation and management service
Face-to-face and non-face-to-face
- Services may include both face-to-face and non-face-to-face activities
- The documentation must identify the two clinicians who shared the visit
- The individual who performs the substantive portion of the visit (and bills for it) must sign and date the encounter
Documentation
“We also are clarifying that when one of the three key components is used as the substantive portion in 2022, the practitioner who bills the visit must perform that component in its entirety in order to bill. For example, if history is used as the substantive portion and both practitioners take part of the history, the billing practitioner must perform the level of history required to select the visit level billed. If physical exam is used as the substantive portion and both practitioners examine the patient, the billing practitioner must perform the level of exam required to select the visit level billed. If MDM is used as the substantive portion, each practitioner could perform certain aspects of MDM, but the billing practitioner must perform all portions or aspects of MDM that are required to select the visit level billed.”
The Substantive portion
Documentation of substantive portion
Example one: NPP spends 20 minutes with patient, physician spends 15 minutes
• Each clinician should document time spent
Report under the NPP who spent > 50% of the time
Example two: NPP and physician each see the patient. Physician documents MDM in its entirety.
Identify both clinicians
Physician should sign and date the record, document the MDM in its entirety
References:
https://codingintel.com/cms-shared
https://public-inspection.federalregister.gov/2021-23972.pdf