2022 proposed fee schedule: CMS designs drastic changes to its split/shared policy

Why This Topic Matters

Split/shared billing affects how facility E/M services are reported and documented. The proposed changes could alter workflow, recordkeeping, and claim submission practices for organizations that use physician and QHP collaboration in hospital and other institutional settings.

Article Sections

1. Proposed CMS split/shared visit policy

   Introduces the proposed update to CMS split/shared visit rules and explains that the plan differs substantially from prior guidance. It also frames the policy as part of the 2022 Medicare physician fee schedule.

2. Core elements of the proposal

   Summarizes the main components CMS says would remain in place and the settings covered by the proposal. It also notes the broader shift in how these visits would be handled.

3. Time-based coding and billing approach

   Describes the move away from prior approaches and toward time-based reporting for non-critical care split/shared services. This section discusses how time would be considered under the proposal.

4. Billing practitioner, documentation, and related policy questions

   Covers proposed billing, recordkeeping, and signature-related expectations, along with CMS’s open questions about groups, emergency department services, and qualifying activities. It also notes industry reaction to the proposal.

5. Compare and contrast: original requirements and proposed update

   Presents a side-by-side comparison of the withdrawn split/shared policy and the proposed update. The comparison highlights differences in setting, service scope, coding approach, and documentation requirements.