As many practices are aware, the split/shared billing rules changed earlier this year, and are in for an even bigger overhaul starting January 1st. If your practice is trying to get ahead of the curve, now is a great time to get a handle on what will change in 2024 and what you’ll need to train your staff so they’re ready before the calendar turns to the new year.
Keep in mind: The 2024 Medicare Physician Fee Schedule Proposed Rule includes a proposal that would delay the changes below until Jan. 1, 2025. However, that proposal is not guaranteed to be finalized, so keep an eye on the Training Leader website as this story develops. Until then, the following changes are still scheduled to take effect on Jan. 1, 2024.
Check out three tips that will ensure your practice is ready for the updated split/shared billing rules in 2024.
1. Train on Documentation Best Practices
The key to a split/shared visit is that the physician performs one part of the E/M visit and a nonphysician provider performs another part of it. The two providers’ notes are combined to select an E/M code, and you’ll submit the claim under the NPI of the provider who performed the “substantive portion.” To get to that last bit, you’ll first need to ensure your providers are making that information clear in the record.
The medical record should identify both providers who were involved in the patient’s care and each should very clearly document what they personally did, with no ambiguity. If you’re finding that it’s difficult to determine which provider performed which portions of the visit, it’s important to set up a training session now so your providers are prepared to clearly document that information before 2024 arrives.
2. Identify “Substantive Portion”
Currently, for facility visits other than critical care, you’re choosing the billing provider as the person who performed the substantive portion of these visits by using one of two methods:
- Utilizing one of the three key components of history, exam or medical decision making, OR
- Calculating more than half the total time of the visit
Beginning on January 1, however, CMS will require you to calculate the substantive portion by evaluating who spent more than half the total time on the visit. That’s already how billers are selecting the provider for split/shared critical care visits, so you’ll start doing all of your split/shared billing that way in 2024.
Now is the time to train your coders, billers and front desk team on how to find this information in the record. You should also ensure that providers are marking their time spent on every task so you can easily add up each provider’s time to determine who qualifies as the substantive provider. In addition, the provider performing the substantive portion of the visit should sign and date the record.
3. Remember That Split/Shared Isn’t Applicable in the Outpatient Setting
These split/shared rules only apply to facility visits and not outpatient encounters. That’s because incident-to applies for outpatient visits, and you’ll instead defer to those rules when you perform a split or shared visit in the office setting. Remind providers, back office staff and other team members of this during your training sessions so they don’t confuse incident-to and split/shared rules.
If you want a sneak peek of 2024 split/shared changes, it might be helpful to understand what changed this year. Let expert Kim Huey, MJ, CHC, CPC walk you through the ins and outs of these confusing services. During her 90-minute online training, “Get Paid 15% More, 2023 Split/Shared & Incident-to Rule,” Kim will help you master the 2023 rules and prepare for 2024. Register today!
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