Ob-Gyn Coding Alert

Question: If Medicare finalized its split/shared visit policy in 2022, why did it reverse its decision?

Tennessee Subscriber

Answer: The Centers for Medicare & Medicaid Services (CMS) lists two reasons in the CY 2023 Medicare Physician Fee Schedule (MPFS) proposed rule to back up that choice.

1) 2023 E/M updates: Effective Jan. 1, 2023, several evaluation and management (E/M) codes will update to fall in line with the 2021 E/M changes to coding for office and other outpatient services. Examples of these codes include 99221-99223 (Initial hospital inpatient or observation care, per day, for the evaluation and management of a patient, which requires a medically appropriate history and/or examination …) and 99281-99285 (Emergency department visit for the evaluation and management of a patient …).

Delaying the split/shared visit policy implementation until 2024 gives providers a transition year to get acclimated to the 2023 E/M guidelines and get their practices up to speed on the incoming changes.

2) Feedback: The delay allows CMS to gather more comments and feedback from interested stakeholders regarding the policy and how it could be altered or further refined.

“I personally feel it’s more advantageous to the providers to have the substantive portion — and have it be either the MDM or the more than half the time — that is going to determine the code,” said Sandy Giangreco Brown, MHA, BS, RHIT, CHC, CCS, CCS-P, CPC, CPC-I, COBGC, COC, PCS, during the “Compliance Issues with Billing for Non-Physician Practitioners” session at AAPC’s HEALTHCON Regional 2022 conference.

In a March 2022 letter to CMS administrator Chiquita Brooks-LaSure, several medical organizations, including the AMA, strongly urged CMS to discontinue its split/ shared visits policy and not move forward with the transition set to take effect in 2023. The organizations felt the policy wouldn’t allow providers to effectively co-manage patients’ needs and was contrary to clinical alignment (https://searchlf.ama-assn.org/letter/documentDownload?uri=/unstructured/binary% 2Fletter/LETTERS/Sign-on-letter-to-CMS-re-Split-or-Shared-Visits-Final-03-29-22.pdf).