Use these practical tips to navigate new split/shared billing rules

Why This Topic Matters

The policy affects how facility-based evaluation and management visits are reported and documented, which can influence reimbursement, compliance risk, and audit exposure. Practices that work with physicians and non-physician practitioners need a clear overview of the applicable settings and documentation expectations.

Article Sections

1. Split/shared policy overview and implementation timing

   Introduces Medicare’s new split/shared policy and the reported implementation timing. Summarizes the confusion it creates in provider-based clinic settings.

2. When split/shared applies versus incident-to

   Compares the two billing approaches by place of service and outlines the settings where each framework is discussed in the article. Focuses on the broad distinction between office and facility environments.

3. Substantive portion and documentation considerations

   Reviews the transition-year concepts used to determine the substantive portion of a shared visit. Discusses broad documentation themes for physicians and non-physician practitioners.

4. Audit risk, specialty impact, and related considerations

   Addresses compliance concerns, documentation updates, and how the policy may affect certain specialties and practice models. Also covers telehealth and payer follow-up at a high level.

5. Sidebar: Transitional guidance from CMS

   Summarizes a CMS open door forum exchange included as background on transitional policy interpretation. Explains that the sidebar provides additional context for the new shared-visit framework.