CMS plans tougher critical care rules along with new split/shared policy

Why This Topic Matters

Critical care coding and billing rules can materially affect whether services are reportable, how time is counted, and which practitioner bills. The proposed CMS changes could alter workflow for groups that provide critical care across specialties or use split/shared care arrangements.

Article Sections

1. Overview of proposed critical care policy changes

   Introduces the CMS proposed rule changes affecting critical care services and places them in the context of the broader Medicare physician fee schedule update.

2. Withdrawal of prior CMS critical care guidance

   Summarizes the earlier withdrawal of CMS manual guidance and the relationship to other Medicare policy changes.

3. Proposed split/shared critical care approach

   Describes the proposed framework for shared critical care billing and the use of time-based aggregation within a practice.

4. CPT prefatory language and qualifying activities

   Notes CMS’s reliance on CPT prefatory language and the general category of activities used to define critical care time.

5. Clarification on concurrent care

   Addresses proposed clarification for concurrent critical care furnished by providers in different specialties.

6. Stricter same-day and global-period rules

   Covers the proposed restrictions on other E/M services on the same date and the treatment of critical care during global surgical periods.

7. Additional time needed for add-on reporting

   Explains that CMS is proposing a revised time threshold before additional critical care reporting can occur when multiple practitioners are involved.

8. Withdrawn guidelines reference

   Provides the cited source reference for the withdrawn CMS manual guidance.