February 4, 2022 | By Scott Kraft, CPMA, CPC
Medicare is making big changes to its policies for billing split/shared visits. While the main policy shifts take place in 2023, there are important changes to the rules for split/shared services in 2022 that must be followed for these services to be covered and billable under the physician.
The 2022 Physician Fee Schedule Final Rule offers two avenues for billing these visit types. The first option, available only in 2022, requires the provider that will bill the service to perform a “substantive” component of the visit.
New to 2022 is the definition of substantive as performance of one of the history, exam, or medical decision-making component of the note in its entirety. As a result, for the physician to bill the visit as split/shared, he or she must completely document one of these areas and it should be documented to support the service assigned to the visit.
Beginning in 2023, whichever of the two providers involved spends more of the documented time on the visit is the one who will bill the service. This policy is also in place for 2022 as an alternative to the substantive component area.
It’s important to note that when using the “majority of time” definition of split/shared, this includes all activities that each provider spends on the patient on the date of service, whether or not these activities are face to face. Examples include reviewing lab or test results, discussing the patient’s care with nurses or other providers and the activities associated with the visit itself.
When using the time method, because the provider billing must spend the majority of time, each provider must document his or her own time in the medical record. This documentation should also account for how each provider spent his or her time on behalf of the patient, though the rule simply states the majority of the time spent defines who bills the service.
Some other important considerations:
- These split/shared rules apply only to Medicare cases and private payers may maintain their own rules.
- Medicare has created a new modifier, FS, to attach to split/shared visit claims.
- Split/shared visit billing is permitted only in facility settings and can no longer be done in place of service 11, even when the requirements of incident to are met.
The transitional year of 2022 provides a clear documentation roadmap to continue to bill split/shared visits this year, albeit with modified documentation requirements. It will take careful consideration to determine a viable model to continue to ensure split/shared visits can be billed under the rendering physician in 2023.
