Make sense of new proposals to revise CPT coding, billing for split/shared visits

September 7th, 2021

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Note:  The following article synopsis was NOT provided by HCPro. It was created by Find-A-Code/innoviHealth.

Article Overview

This article reviews proposed CMS changes to how split/shared visits would be reported under Medicare, with emphasis on hospital-based evaluation and management services, time-based reporting concepts, modifier use, and documentation expectations. It is aimed at physicians, qualified healthcare professionals, coders, billers, and compliance staff who need to understand how the proposal could affect workflow and reimbursement processes.

Why This Topic Matters

Split/shared visit policies affect how Medicare claims are assigned, documented, and tracked across physician and QHP collaboration. Understanding the proposal helps practices assess operational impact, documentation readiness, and potential compliance changes before the rule becomes final.

Article Sections

  1. Overview of the proposed CMS changes

    Introduces the 2022 Medicare Physician Fee Schedule proposal and summarizes the overall policy shift affecting split/shared visit reporting.

  2. Core elements of the proposed split/shared policy

    Covers the general setting, practitioner relationship, and service types addressed by the proposal, along with areas CMS says would remain unchanged.

  3. Time-based reporting and practitioner attribution

    Discusses the proposed move toward time-based selection concepts and how CMS would attribute the service for reporting purposes.

  4. Overlapping time and related ambiguities

    Summarizes CMS guidance on overlapping time and notes areas where the proposal leaves unanswered operational questions.

  5. Other proposed revisions

    Reviews additional proposed changes involving a new modifier, documentation expectations, and related tracking requirements.

  6. CMS requests for public comment

    Outlines the broader policy topics CMS seeks feedback on, including group definition and emergency department-specific considerations.

  7. Early reaction hints at pushback

    Presents commentary from industry experts reacting to the proposal and describing likely implementation concerns.

What You Will Learn

  • How CMS is proposing to revise split/shared visit reporting for Medicare
  • Which service settings and practitioner arrangements are implicated by the proposal
  • How time-based concepts are being introduced into split/shared visit policy
  • What new documentation and tracking elements are being considered
  • Which related policy areas CMS is seeking public comment on
  • How industry observers are reacting to the proposed changes

Who Should Read This

  • Physicians
  • Qualified healthcare professionals
  • Medical coders
  • Medical billers
  • Practice managers
  • Compliance staff

Modifiers Discussed

  • HCPCS Level II: modifier

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