Billing rules: CMS extends its split/shared exception for facility-based visits

Why This Topic Matters

The update affects how facilities and practices assign billing responsibility for split/shared encounters and when the revised policy takes effect. It also highlights the need for internal staff education because CMS policy and CPT guidance are not identical.

Article Sections

1. Overview of the CMS split/shared delay

   Introduces the policy update and the revised effective date for the split/shared exception in facility-based visits. It frames the change in the context of Medicare billing operations.

2. Retention of key components confused commenters

   Discusses stakeholder questions about how CMS treats the key elements of an encounter in relation to level-based visit reporting. It addresses the broader issue of how the guidance interacts with the 2023 update to the visit code set.

3. New definitions could be in the works

   Covers the relationship between CMS split/shared policy and CPT guidance, including the possibility of future clarification. It also notes the role of AMA/CPT review and possible future rulemaking.