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SHM Secures Further Delay to Changes to the Split (or Shared) Billing Policy

July 17, 2023

On July 13th, 2023, the Center for Medicare and Medicaid Services (CMS) published the CY2024 Physician Fee Schedule proposed rule. In this rule, CMS has proposed to delay the implementation of the time-based definition of a “substantive portion” of a split (or shared) visit through at least December 31st, 2024. This delay is a result of vocal and consistent advocacy from SHM and other key stakeholders.

In the 2022 Physician Fee Schedule, CMS created a new time-based policy for billing split (or shared) visits. Under the finalized policy, only the clinician who performs a “substantive portion [of the visit],” meaning the clinician who spent more than half the total time on the split (or shared) visit, would be able to bill for the entire visit. However, time is challenging to track across multiple clinicians and dramatically disrupts team-based care in the hospital. It also upends long-established billing and documentation systems and creates significant, new administrative burdens. SHM is pleased CMS has extended this delay, as it will give us more time to work with them to develop a policy that better accommodates the reality of team-based care.