Pulmonology Coding Alert

Question: I remember the Centers for Medicare & Medicaid Services (CMS) putting a hold on only using time as the basis for the substantive portion of split/shared billing for 2023. Has there been any update on this policy for 2024?

Arkansas Subscriber

Answer: Yes, there is updated news on this policy. In their 2024 Medicare Physician Fee Schedule (MPFS) proposed rule, CMS is proposing to continue allowing providers to determine whether a physician or an advanced practice provider (APP) furnished the substantive portion of a split/shared evaluation and management (E/M) visit based on these criteria:

• Who performed a substantive component of history, physical exam, or medical decision making (MDM) in its entirety; or
• Who spent more than half of the total time with a patient.

CMS originally proposed shifting the substantive portion as solely a time-based factor in 2023, but many healthcare professionals strongly opposed the policy change, and requested that CMS rescind the proposal. The agency then delayed the transition to using time as the only factor for the substantive portion of a split/shared visit until 2024. However, CMS is proposing to delay the change once again.

“This proposed additional delay would allow stakeholders another opportunity to comment on this policy. CMS is also interested in how facilities are currently implementing the delayed split/shared services policy,” wrote McDermott+Consulting in online analysis (www.mcdermottplus.com/insights/cms-releases-cy-2024- physician-fee-schedule-proposed-rule/).

Check back with Pulmonology Coding Alert for further updates when the 2024 MPFS is finalized.