Date Posted: Monday,
May 30, 2022
Got five minutes? You can learn five things about the crazy 2022 rules for Split Visits. Hopefully, this will end a lot of the confusion around these relatively new rules.
One
Split visits, as defined here, do not apply to splitting time with staff people (MAs, RNs, etc.). These rules apply only to physicians and Advanced Practice Professionals (APPs).
Two
For 2022, there are no new rules for APPs working "incident to" a physician in the office setting. There are no changes in 2022 for APP billing in place of Service 11.
Three
Also in 2022, in most settings, nurse practitioners and physician assistants can bill under their numbers. For most services (but not drugs), there will be an allowable reduction of 15%.
Four
Where this does apply is when a physician and an APP both see the patient in a hospital or other institutional settings. They must be in the same group. In 2022, who bills depends upon one of two criteria. The first criterion is time; that is, who spent greater than half the total time with the patient. The total time determination is defined similarly to the 2021 office-based coding requirements. Second, billing can depend upon which clinician does a complete component of E/M documentation (history, physical, or medical decision making). This will change in 2023 when the documentation guidelines for non-office visits change.
Five
Whoever bills for the service must sign and date the note. The visit must be appended with Modifier – FS.
Five Minute Fixes
- Physicians compensated based on work RVUs (wRVUs) should have someone compute how the new policy might impact their compensation and/or hospital time in the future.
- If APPs round more than physicians in your practice, the change in rules may profoundly impact your revenue as visits will be reduced by 15%. The adjustment can be more significant than you think as these rules apply to new and established patients.
- Remember Split Visit rules apply to Medicare patients only. You may have to change your workflow for these patients; however, you should determine how private payers handle these visits in your area before finalizing any changes.
- Audit a sample of hospital visits with Modifier – FS. Is it clear who performed a substantive part of the visit? Did they sign and date the record? Is the bill date the same as the note date (a long-standing problem with hospital documentation)?
- Don’t let this be the only article you read on the subject. It is complicated. I recommend an article written by hsgadvisors.com (see https://hsgadvisors.com/articles/the-2022-cms-split-shared-visit-rules-and-the-anticipated-impacts/), but there are dozens of good references on the subject.
Bobbi Buell, MBA
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