Clearing the Confusion: Updates on Split/Shared Rules and Guidelines

Clearing the Confusion: Updates on Split/Shared Rules and Guidelines
One thing is certain about the healthcare field – it’s ever-changing. Earlier this year, many practices learned about the changes in split/shared billing rules, resulting in pushbacks due to the potential impact on day-to-day workflows, physician compensation, net revenue, and potential economic impact on the traditional team-based care model. With this, the Centers for Medicare and Medicaid Services (CMS) recently updated the new time-based requirement for 2024. At Synapse, we aim to clear up the confusion about the new split/shared rules and help you get ahead of the curve.

2024 Medicare Physician Fee Schedule Proposed Rule

On November 2, the Centers for Medicare and Medicaid Services (CMS) released the final rule on the 2024 Medicare Physician Fee Schedule, which states that the 2024 conversion factor (i.e., the amount Medicare pays per relative value unit) is reduced to $32.74 compared to $33.89 from 2023. Secondly, family doctors and others can report and get paid for the G2211 code with many E/M services. Next, CMS extended multiple telehealth flexibilities, which you can check on their site. Advancing health equity by finalizing several coding and payment policies is done by the CMS as well.

The good news: There is no increase in the Merit-based Incentive Payment System (MIPS) performance threshold, reducing the chances of negative payment adjustment in 2026. Most importantly, working with Synapse guarantees you are given the essential information to rise above the noise and learn about the latest developments. If you wish to talk with a medical billing expert, you can use the contact form on our site and we will get back to you as soon as possible.

What is a Split/Shared Visit?

A split (or shared) visit is defined by the Medicare Claims Processing Manual as “an evaluation and management (E/M) visit in the facility setting that is performed in part by both a physician and a nonphysician practitioner (NPP) who are in the same group, in accordance with applicable law and regulations such that the service could be billed by either the physician or NPP if furnished independently by only one of them.”

At present, there are two methods to determine who performed the substantive portion of these visits: Either we utilize one of the three key components of history, exam, or medical decision-making or calculate more than half the total time of the visit. However, starting January 1, CMS requires you to evaluate who spent more than half the total time on the visit and they would sign and date the record. This also means your coders, billers, and front desk team need additional training on how to find this information in the record, ensuring that each provider’s time is added up to know the substantive provider.

Tips to Keep Up with the Split or Shared Service Changes

Before the calendar turns to 2024, this is a wonderful time to get a handle on these changes and flow with the overhaul beginning January 1st. Here are helpful tips to ensure you are prepared for the updated split/shared billing rules in 2024.

Documentation training: Remember, you’ll need to submit a claim under the NPI of the provider who performed the “substantive portion.” To ensure you have the substantive provider, your staff should identify both providers who were involved in the patient’s care and what they clearly did with absolute clarity. Setting up a training session for proper documentation can greatly give you an advantage before 2024 comes.

Be mindful: Facility visits and not outpatient encounters are applicable to split/shared rules. Make sure to let your providers, back office staff, and other team members know that incident-to only applies to the latter. Moreover, accurately counting all physician time is crucial. To clearly determine the substantive portion, you can check this list of activities that count toward the total time (face-to-face or not).

Here are some of the services that qualify for time:

  • Reviewing medical records and notes from external sources to prepare to see the patient
  • Performing a medically appropriate exam or evaluation.
  • Counseling and educating the patient, family, and/or caregiver
  • Ordering medications, tests, or procedures
  • Referring and communicating with other health care professionals (not separately reported)
  • Documenting clinical information in the electronic or other health record
  • Independently interpreting results (not separately reported) and communicating results to the patient/family/caregiver.

With Synapse’s support, you don’t have to break a sweat for the changes that the next year will bring. We have highly trained billers and coders who are equipped with the skills to get ahead of updates and new rules. All it takes is one call from us and we can schedule with our billing and coding team for personalized and tailored fit solutions for your practice. Together, let’s give ourselves a headstart before the clock strikes 12 on January 1 by contacting us at medicalsales@synhs.com or (844) 384 7532.