In Brief: Despite the delay, organizations need to start preparing for implementation now.
The Centers for Medicare & Medicaid Services (CMS) released its proposed 2024 Medicare Physician Fee Schedule rule on July 13, addressing Medicare payments for physicians with provisions that address quality, affordability, and innovation for 2024. CMS is proposing several changes under the rule, including lowering the physician conversion factor by 3.34%, in conjunction with increasing payments for primary care providers by implementing a separate add-on payment to recognize the additional resources utilized for evaluation and management (E&M) visits and longitudinal care of complex patients.
But in what may be its most anticipated decision, CMS is proposing to delay the implementation of its definition of the “substantive portion” for split/shared E&M inpatient visits at least through 2024. This delay will give organizations time to understand and prepare for the implications of the change.
CMS defines a split/shared E&M visit as one performed by both a physician and an advanced practice provider (APP) who are in the same specialty and group practice. Historically, the physician was required to perform the substantive portion of the E&M visit, and the visit was billed under the physician.
Upon implementation, CMS will change the definition of the substantive portion of a split/shared inpatient E&M visit to a time-based definition, moving away from a medical decision-making approach. The “substantive portion” will be defined as the “physician or APP who spends more than half the total visit time with a patient.” The policy change applies to only those E&M visits performed in the facility setting.
Although the rule change has been delayed, all organizations will need to prepare for this change and address its anticipated implications.
A Deeper Dive on Split/Shared Billing
In an upcoming blog series, ECG will address the implications of CMS’s billing policy change for split/shared E&M visits in the facility setting. We’ll identify potential impacts of the split/shared E&M changes to key areas such as:
- Documentation and compliance.
- Revenue.
- Provider compensation models.
- Fair market value.
- Operations and practice models.
With each blog post, ECG will provide strategies to help your organization be proactive in addressing the regulatory changes of the final rule.
Edited by: Matt Maslin
Published July 14, 2023