In anticipation of changes to the current split or shared services policy, AAPM&R has submitted comments to the Centers for Medicare & Medicaid Services (CMS) highlighting concerns with the changes expected to go into effect January 1, 2023.
In the 2022 Medicare Physician Fee Schedule, CMS announced that it would change its split or shared services policy effective 2023 to require that shared services be reported by the provider who provides more than half of the time of the service. With billing being tied only to time, rather than medical decision making, the new policy runs the risk of negatively impacting physicians who may spend less time with the patient but shoulder more of the cognitive workload. AAPM&R strongly disagrees with this policy and seeks to encourage CMS to revise the policy to allow medical decision making to be a deciding factor in split or shared services billing.
In addition to submitting an Academy letter, AAPM&R has signed on to similar joint statements submitted to CMS by the American College of Physicians and the American Medical Association. We anticipate additional advocacy on this issue will be necessary throughout 2022.