decisionhealth Newsletters, Part B News - 2021 Issue 11 (November)
CMS widens scope of split/shared policy, firms up billing rules
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Article Overview
This article covers CMS’s updated guidance for split/shared facility evaluation and management services under the 2022 Medicare physician fee schedule. It is aimed at billing, coding, compliance, and revenue cycle professionals who need to understand how the policy changes affect facility-based encounters, documentation, and reporting requirements during the transition period. The discussion focuses on the broad structure of the new rules, who should bill, how the substantive portion is determined, where the policy applies, and the new reporting modifier introduced by CMS.
Why This Topic Matters
The policy change affects how split/shared visits are documented and billed in facility settings, which can influence compliance risk, workflow, and reimbursement. Practices need to understand the transition period and the future shift to a single billing approach.
Article Sections
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Billing
Introduces the 2022 changes to split/shared facility billing and the overall shift in CMS policy. Summarizes the main areas of impact for practices that report these services.
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Calculating ‘substantive portion’
Explains the approaches CMS allows for determining the substantive portion of a visit during the transition period. Focuses on documentation and the general billing framework for the updated policy.
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Time-based billing could free physician time
Discusses CMS commentary on time-based reporting and related operational considerations. Notes broader workflow implications for practitioners and groups adapting to the new requirements.
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Be careful with two challenging areas
Highlights transition-related implementation issues and areas that may create confusion for compliance and education efforts. Addresses the temporary nature of one option and the need to plan for the later phase of the policy.
What You Will Learn
- How CMS updated the split/shared billing framework for 2022
- What types of facility encounters the guidance applies to
- How the transition period affects reporting options
- What documentation and operational issues practices should consider
- Why the policy matters for compliance and revenue cycle workflows
Who Should Read This
- Medical coders
- Billing staff
- Compliance professionals
- Practice managers
- Revenue cycle teams
- Physician advisors
Codes Discussed
Code Ranges Discussed
Modifiers Discussed
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