decisionhealth Newsletters, Coder Pink Sheets - 2022 Issue 11 (November)
CMS extends its split/shared exception for facility-based visits
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Article Overview
This article summarizes CMS’s final-rule update affecting split/shared billing for facility-based visits, including the revised effective date and the continued focus on who performs the key elements of the encounter. It also places the CMS policy in context with CPT split/shared guidance and notes that further refinement may be considered in future rulemaking. The piece is relevant for practices, coders, and compliance staff who work with evaluation and management services and need to track federal policy changes.
Why This Topic Matters
The timing and definition of split/shared billing can affect how facility-based E/M visits are reported and which provider is associated with the service. Understanding the CMS update helps practices prepare for policy changes and distinguish CMS requirements from CPT guidance.
Article Sections
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Policy timing update
Discusses CMS’s revised effective date for the split/shared policy update and the related transition period for practices.
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Retention of key components confused commenters
Reviews the policy discussion around encounter elements used in split/shared billing and the questions raised by commenters about how the update fits with broader E/M changes.
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New definitions could be in the works
Explains the relationship between CMS split/shared policy and CPT guidance, including the possibility of future review or rulemaking.
What You Will Learn
- How CMS updated the effective date for its split/shared policy
- Why the CMS approach differs from related CPT split/shared guidance
- What general issues practices should review when applying split/shared billing policies
- How future CMS or CPT changes may affect split/shared definitions
Who Should Read This
- Medical coders
- Compliance staff
- Physician practices
- Facility-based billing teams
- Revenue cycle professionals
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