Oncology & Hematology Coding Alert

Split/shared definitions, critical care bundling, care management revaluation and a CF decrease lead the way.

For the most part, the positives in the Final Rule for 2022 outweigh the negatives. CMS has adopted many of the proposals we featured in “Take Care to Comprehend CMS’ Critical Care, CCM Proposals for 2022” in Oncology and Hematology Coding Alert vol. 23 issue 9, and they have positively revalued the chronic care management (CCM) code family.

But before you celebrate the good news, you should know the Final Rule has a sting in its tail. Read on if you want to know how it will affect your practice next year.

1. Fixate on this Final Split/Shared Proposal and “Substantive Portion” Definition

Medicare finalized its proposal to simplify its split/shared policy by “limiting the definition of split (or shared) visits to include only evaluation and management (E/M) visits in institutional settings … and for critical care and certain Skilled Nursing Facility/Nursing Facility (SNF/NF) E/M [evaluation and management] visits.” Additionally, you’ll be able report these visits for both new and established patients.

But you will have to keep one eye on the calendar if you do. For while the finalized version of the split/shared rule calls for billing the visit under the physician or non-physician practitioner (NPP), your billing will be dependent on who performs the substantive portion of the visit. For CY 2022, CMS will define substantive portion as “one of the three key components (history, exam, or MDM [medical decision making]), or more than half of the total time spent by the physician and NPP performing the split (or shared) visit). In other words, for CY 2022, the practitioner who spends more than half of the total time, or performs the history, exam, or MDM can be considered to have performed the substantive portion and can bill for the split (or shared) E/M visit.”

After Jan. 1, 2023, however, the substantive portion will just be calculated on time and not on one of the classic 3 E/M elements (history, examination, or MDM).

2. Begin Bundling Critical Care Like CPT^®

CMS will now define and bundle critical care codes 99291 (Critical care, evaluation and management of the critically ill or critically injured patient; first 30-74 minutes) and +99292 (… each additional 30 minutes …) the same way as CPT^® beginning Jan. 1, 2022, as we previously reported. They will also apply the same definition of split/ shared to these codes as well.

3. Be Positive About This CCM, Complex CCM, and PCM Revaluation

As for the fee schedule itself, “One piece of good news in the final rule is that CMS is increasing payment for chronic care management (CCM) services,” says Kent Moore, senior strategist for physician payment at the American Academy of Family Physicians.

The table below shows the increase in relative value units (RVUs) for the old codes, and the valuation of the codes CMS is introducing this year.

4. But Lower Your CF Expectations