Successful split/shared implementation for your organization

9 minute read

If your healthcare organization utilizes split/shared billing, your organization could be at risk without proper training and attestation to support services billed correctly. If you are unfamiliar with split/shared services, it’s the practice of two providers: a physician and a qualified healthcare professional (QHP) see a patient on the same day, and one of them decides to bill based on a “discussion” with the QHP as well as attestation of the QHP note. As such, the Centers for Medicare & Medicaid Services (CMS) has modified guidelines with documentation requirements as well as the elements of medical decision-making related to the care provided. The Final Rule was published in the November 18, 2022, Federal Register—an annual publication of confirmed regulatory requirements to bill these and other types of services to CMS.[1] It explained how the proper documentation requirements to bill for split/shared services would be granted another year extension from calendar year (CY) 2023 to CY 2024. This means that when split/shared services are billed, documentation requires—per CMS—the physician or the QHP to detail a substantive portion through history, examination, or medical decision-making (MDM) more than half of the total time. CMS intends to change the documentation from history, examination, or MDM to only total time beginning in CY 2023. With this additional year in place, organizations have more time to train their providers of services to meet these regulatory requirements.

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