2022 CMS guidelines for physician assistants and nurse practitioners revolve around split/shared rules. To bill correctly this year, you need to realize who these rules apply to and how to document them to comply with Medicare.

What are Shared or Split Services?

Shared or split services refer to E/M services, an abbreviation for evaluation and management. These services are combined with a non-physician practitioner and a professional physician, and both individuals must also be from the same facility and group. The split or shared services rule will apply to any health care professional conducting an evaluation and management during their practice. Therefore, it also applies to physical practitioners and orthopedic practices. The split service rule became applicable because Medicare pays 100% of the fee schedule for physicians and 85% for practitioners who are not physicians. If they are providing their services together, then the physician should be responsible for performing a more significant portion of the evaluation and management service. This rule is for someone that can bill for CMS practices personally and is not for sharing work with a resident or staff member.

How to Perform Shared Service?

To benefit from split services, you must report all services and bills under the entity responsible for the service’s substantive part. You then have to determine and recognize the names of all physicians and non-professional physicians who contributed to the service. Furthermore, the healthcare practitioner responsible for the more significant portion of the service must date the medical record and provide it with their signature. A new modifier, which pertains to split and shared evaluation and management services, has also come into play. If you were performing shared services in 2021, Medicare would have no way of identifying what services you were performing, split, or shared. The claim would go under the physician or NPP’s provider’s number, and you wouldn’t know about the service.

Where can you Perform Split/Shared Services?

CMS will now be able to review, look up, and identify all split and shared services by healthcare professionals. CMS can identify these services based on the modifier. You can perform these services in a facility or an institution, and many service codes constitute a facility. These facilities can be emergency departments, nursing facilities, provider-based clinics, or campus outpatient hospitals.

Substantive Portion

The substantive portion of service can be defined either by time or key components. If you are using the time to define an outpatient visit code, which will determine the substantive portion, then you have to bill it under the practitioner who spends more than 50% of their time. One of the practitioners must have a face-to-face service with the patient. When implementing this service, the deciding point will determine who has done the most work. If you want professional expertise to help with that, contact us, or fill out our online form.