The AAMC joined other health organizations in a March 29 letter to the Centers for Medicare & Medicaid Services (CMS) Administrator Chiquita Brooks-LaSure urging the agency to rescind the policy that was finalized in the 2022 Physician Fee Schedule Payment rule regarding who should bill for split/shared visits.
Under this policy, the physician or nonphysician practitioner (NPP) who bills more than 50% of the time of the total visit would bill for the split/shared visit beginning in 2023. The letter explained that this policy would discourage team-based care and interfere with care delivery. It recommended that the CMS propose an alternative policy that would allow physicians and NPPs to bill split/shared visits based on either time or medical decision-making. The medical decision-making typically does not involve the most time; however, it is essential to determining the patient’s course of treatment.
The AAMC first expressed strong opposition to the policy regarding time when it was proposed in the 2022 physician fee schedule rule [refer to Washington Highlights, Sept. 17, 2021].