Title: 2023 And Beyond: The Evolution Of Split Shared Billing In Medicare
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22023 And Beyond The Evolution Of Split Shared
Billing In Medicare
- Physician assistants (PAs) and nurse
practitioners (NPs), collectively known as
advanced practice providers (APPs), play a vital
role in healthcare across various specialties.
Their responsibilities, including billing for
clinical and procedural services, have evolved
significantly. In particular, the Centers for
Medicare and Medicaid Services (CMS) has
implemented substantial changes to split/shared
billing policies, impacting APPs and physicians
treating patients collaboratively. To understand
these changes, tracing the historical timeline
that led to the evolution of split/shared billing
services in the United States is essential. - Read Detailed Blog _at_ https//www.247medicalbilling
services.com/blog/split-shared-billing-in-medicare
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32023 And Beyond The Evolution Of Split Shared
Billing In Medicare
- Historical Background
- Before 1997, CMS recognized NPs and PAs as
facility support staff, reimbursed through the
hospitals cost report without Part B billing.
The Balanced Budget Act of 1997 marked a pivotal
shift, allowing APPs to be recognized as Part B
providers. While advancing clinical practice,
this change posed financial challenges as APP
salaries could no longer be included in the
hospitals cost report. To address this, CMS
introduced the practice of split/shared billing,
enabling joint billing for Evaluation and
Management (E/M) services by physicians and APPs. - The Split/Shared Practice
- The split/shared practice allows E/M services
jointly performed by a physician and APP to be
billed at 100 of the Medicare Physician Fee
Schedule (MPFS) under the physicians name and
National Provider Identifier (NPI) number.
Historically, these services were often billed
under the physicians name, with minimal
requirements on physician participation or
documentation levels. However, as part of its
annual rulemaking process, CMS updated the
split/shared guidelines in 2022, introducing
significant modifications.
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42023 And Beyond The Evolution Of Split Shared
Billing In Medicare
- Changes in 2022
- Attribution of Billing
- Billing should be attributed to the provider
(physician or APP) who spent the substantive
portion of time, defined as greater than 50, in
the patients care on that calendar day. - Critical Care and Skilled Nursing Facility
Services - Critical care services and certain skilled
nursing facility (SNF) services can be
split/shared, and a billing modifier FS should
be appended to all split/shared services. - Documentation and Billing Modifier
- The rules emphasize that billing should align
with the provider (physician or APP) who
performed the substantive portion of time. In
fact, a billing modifier FS is mandated for all
split/shared services, enabling Medicare to
identify shared services and facilitating
additional scrutiny and targeted payer auditing.
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52023 And Beyond The Evolution Of Split Shared
Billing In Medicare
- Transition Period
- The implementation of these changes began in 2022
and continued into 2023, labeled as a
transitional year. In fact, critical care
services, including split/shared critical care,
are solely time-based during this transitional
period. Meanwhile, non-critical care services can
be attributed either to time or the performance
of history, examination, or medical
decision-making (MDM). - Transition to Time-Based Attribution
- CMS plans to move to a solely time-based
attribution model in 2024. While the 2022 rule
aimed to align with current clinical practice,
its impact on the team-based care model and
revenue expectations remains uncertain. The shift
to time-based billing raises questions about
documentation expectations, potential fraud
risks, and the need for clear guidance from CMS. - Unclear Documentation Requirements
- While physicians generally bill non-critical care
split/shared visits under the MDM rubric at 100
of the MPFS, but the specific documentation
requirements are unclear.
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62023 And Beyond The Evolution Of Split Shared
Billing In Medicare
- Impact on Billing Practices
- Under the MDM rubric, non-critical care
split/shared visits are generally billed by
physicians at 100 of the MPFS, provided all
billing requirements are met. However, confusion
persists as the rules do not clearly outline
these requirements. For instance, face-to-face
visits by either the physician or the APP are
necessary, but the rule doesnt specify that the
billing provider must perform this part of the
visit. The lack of clarity around documentation
levels and the requirement for both the physician
and APP to be employed by the same group has
contributed to confusion within healthcare
institutions.
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72023 And Beyond The Evolution Of Split Shared
Billing In Medicare
- Final Thoughts The evolution of split/shared
billing - The evolution of split/shared billing in Medicare
reflects a dynamic interplay between regulatory
changes, financial considerations, and the need
for clarity in documentation and attribution. As
CMS moves towards a time-based model, healthcare
providers face challenges adapting their billing
practices and ensuring compliance. - Outsourcing to 24/7 Medical Billing Services
emerges as a strategic solution, offering
expertise to navigate the complexities of
regulatory changes. Such a professional medical
billing company specializes in staying abreast of
the latest guidelines, ensuring accurate billing,
and mitigating the risk of non-compliance. By
entrusting billing processes to these
professionals, healthcare providers can
streamline operations, enhance efficiency, and
focus on delivering high-quality patient care.
Outsourcing becomes a valuable ally in
maintaining financial stability, fostering
adaptability to evolving regulations, and
ultimately contributing to sustained growth in
the healthcare industry.
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9Call us Today
Media Contact 24/7 Medical Billing
Services, 28405 Osborn Road, Cleveland, OH,
44140 Tel 1 -888-502-0537 Email
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