2023-and-Beyond-The-Evolution-of-Split-Shared-Billing-in-Medicare-scaled.pptx

2023 And Beyond: The Evolution Of
Split Shared Billing In Medicare
Physician assistants (PAs) and nurse practitioners (NPs), collectively known as advanced practice providers
(APPs), play a vital role in healthcare across various specialties. Their responsibilities, including billing for
clinical and procedural services, have evolved significantly. In particular, the Centers for Medicare and Medicaid
Services (CMS) has implemented substantial changes to split/shared billing policies, impacting APPs and
physicians treating patients collaboratively. To understand these changes, tracing the historical timeline that led
to the evolution of split/shared billing services in the United States is essential.
Read Detailed Blog @ https://www.247medicalbillingservices.com/blog/split-shared-billing-in-medicare/
https://www.247medicalbillingservices.com info@247medicalbillingservices.com

Historical Background
Before 1997, CMS recognized NPs and PAs as facility support staff, reimbursed through the hospital’s cost report
without Part B billing. The Balanced Budget Act of 1997 marked a pivotal shift, allowing APPs to be recognized as
Part B providers. While advancing clinical practice, this change posed financial challenges as APP salaries could no
longer be included in the hospital’s cost report. To address this, CMS introduced the practice of split/shared billing,
enabling joint billing for Evaluation and Management (E/M) services by physicians and APPs.
The Split/Shared Practice
The split/shared practice allows E/M services jointly performed by a physician and APP to be billed at 100% of the
Medicare Physician Fee Schedule (MPFS) under the physician’s name and National Provider Identifier (NPI) number.
Historically, these services were often billed under the physician’s name, with minimal requirements on physician
participation or documentation levels. However, as part of its annual rulemaking process, CMS updated the
split/shared guidelines in 2022, introducing significant modifications.

Changes in 2022
• Attribution of Billing
Billing should be attributed to the provider (physician or APP) who spent the substantive portion of time, defined as
greater than 50%, in the patient’s care on that calendar day.
• Critical Care and Skilled Nursing Facility Services
Critical care services and certain skilled nursing facility (SNF) services can be split/shared, and a billing modifier “FS”
should be appended to all split/shared services.
• Documentation and Billing Modifier
The rules emphasize that billing should align with the provider (physician or APP) who performed the substantive
portion of time. In fact, a billing modifier “FS” is mandated for all split/shared services, enabling Medicare to identify
shared services and facilitating additional scrutiny and targeted payer auditing.

• Transition Period
The implementation of these changes began in 2022 and continued into 2023, labeled as a transitional year. In fact,
critical care services, including split/shared critical care, are solely time-based during this transitional period.
Meanwhile, non-critical care services can be attributed either to time or the performance of history, examination, or
medical decision-making (MDM).
• Transition to Time-Based Attribution
CMS plans to move to a solely time-based attribution model in 2024. While the 2022 rule aimed to align with current
clinical practice, its impact on the team-based care model and revenue expectations remains uncertain. The shift to
time-based billing raises questions about documentation expectations, potential fraud risks, and the need for clear
guidance from CMS.
• Unclear Documentation Requirements
While physicians generally bill non-critical care split/shared visits under the MDM rubric at 100% of the MPFS, but the
specific documentation requirements are unclear.

Impact on Billing Practices
Under the MDM rubric, non-critical care split/shared visits are generally billed by physicians at 100% of the
MPFS, provided all billing requirements are met. However, confusion persists as the rules do not clearly outline
these requirements. For instance, face-to-face visits by either the physician or the APP are necessary, but the
rule doesn’t specify that the billing provider must perform this part of the visit. The lack of clarity around
documentation levels and the requirement for both the physician and APP to be employed by the same group
has contributed to confusion within healthcare institutions.

Final Thoughts : The evolution of split/shared billing
The evolution of split/shared billing in Medicare reflects a dynamic interplay between regulatory changes,
financial considerations, and the need for clarity in documentation and attribution. As CMS moves towards a
time-based model, healthcare providers face challenges adapting their billing practices and ensuring
compliance.
Outsourcing to 24/7 Medical Billing Services emerges as a strategic solution, offering expertise to navigate the
complexities of regulatory changes. Such a professional medical billing company specializes in staying
abreast of the latest guidelines, ensuring accurate billing, and mitigating the risk of non-compliance. By
entrusting billing processes to these professionals, healthcare providers can streamline operations, enhance
efficiency, and focus on delivering high-quality patient care. Outsourcing becomes a valuable ally in maintaining
financial stability, fostering adaptability to evolving regulations, and ultimately contributing to sustained growth in
the healthcare industry.

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Call us Today :
Media Contact –
24/7 Medical Billing Services,
28405 Osborn Road,
Cleveland, OH, 44140
Tel: + 1 -888-502-0537
Email: info@247medicalbillingservices.com
Website: https://www.247medicalbillingservices.com/

2023-and-Beyond-The-Evolution-of-Split-Shared-Billing-in-Medicare-scaled.pptx

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