As part of the rulemaking cycle for the 2022 Medicare Fee Schedule (MFS), CMS included in its July 2021 proposed rule policy changes affecting split/shared visits (described below).
Among these was a proposal that would redefine the “substantive portion” of a shared visit as more than half of the total time spent by the physician and the advanced practitioner performing the visit, regardless of medical decision making (MDM).
RPA adamantly opposed implementation of this provision in our comments on the proposed rule, and in the 2022 final rule (released in November 2021) CMS delayed implementation of the revised definition until 2023.
Florida Women in Nephrology Chair
FSN President
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