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CMS updates split shared services policies

The Centers for Medicare and Medicaid Services (CMS) has made refinements to current policies for split shared services.

Longstanding split shared services policies for Evaluation and Management visits were made to better reflect the current practice of medicine, the developing role of the non-physician practitioner (NPP) and clarify condition of payment that must be met to bill Medicare.  

The CMS defines split shared Evaluation and Management services as those performed jointly by a physician and non-physician practitioner (NPP) within the same group provided in the facility setting (i.e., outpatient department 99202-99205, 99211-99215, inpatient 99221-99223, 99231-99233, critical care 99291-99292, emergency department 99281-99285, and skilled nursing facility 99304-99306, 99307-99310). The visit is billed by the physician or non-physician practitioner who provides the substantive portion of the visit.

These visits can be for new or established patients.

A new modifier - FS (split or shared evaluation and management visit) - has been created by CMS. It is now required to be reported on the claim to identify split shared visits and will need to be added to the claim whether the physician or NPP bills for the visit.  

Documentation in the medical record must identify the two individuals who performed the visit. The individual providing the substantive portion must sign and date the medical record.

During this transitional year, the billing of split shared services may be based on time or key components (history or physical exam or medical decision making). When one of three components is used as the substantive portion, the practitioner who bills the visit must document that component in its entirety in order to bill.  

If billing based on time, providers are required to document their total amount. The provider who spent more than 50% of the total time is the one who would bill for the service.

When billing for split shared services, it is important to remember that the Evaluation and Management guidelines are to be followed.

In 2023, split shared services will be based on who spent greater than 50% of total time only.

Medical necessity of a service is the overarching criterion for payment in addition to the individual requirements of a CPT code. Documentation is also key.

If you have any additional questions please contact Claire Niles (860-271-4382), Salma Tahir (646-895-4038) or Erica Murphy (475-248-6515), physician revenue compliance auditors, Office of Privacy & Corporate Compliance.