Shared Visits – Still Puzzled?

Many things changed in 2023. Shared/Split services wasn’t one of them. E/M (Evaluation and Management) services in the office (POS 11) changed dramatically in 2021. Along with it, CMS also changed the Shared/Split rules clarifying that these services may not occur in the office setting. Only visits meeting Incident-to criteria are allowed in the clinic/office (POS 11) setting.

Additionally, CMS changed how physicians utilized Advance Practice Providers by implementing a “Substantive” portion criteria to Shared/Split services. The substantive portion defines who gets to report the E/M service based on who met the criteria, remainder of the guidelines remain unchanged. You still need to be in the same group practice and the service has to occur on the same calendar day. Novitas has the Shared/Split guidelines on their page.

Substantive Portion Criteria: (2024 Update: use MDM or Time only)

A.  Either document one of three (History, Exam, or MDM) key components in its entirety, or

B.  Document that you spent >50% of the combined total time reported

1. Critical Care – Substantive Portion = >50% of the total time only.
2. Emergency Department – Substantive Portion = 1/3 key components only.
3. Activities that contribute to the total time are the same as what was implemented by CPT for the office/clinic setting in 2021.
4. CMS delayed the implementation for using time only to determine the substantive portion.

The AAPC shared examples of documenting the substantive portion in their Updates Clarify Medicare Split/Shared article.

“I provided a substantive portion of the care of this patient. I personally performed the ______________ for this encounter.” (Insert history, exam, or MDM, followed by documentation of the history, exam, or MDM to the extent needed to support the assigned E/M code.)

“I provided a substantive portion of the care of this patient. I personally provided more than half of the total time dedicated to the treatment of this patient.”

Modifier -FS (Shared/Split E/M visit) must be appended to the E/M CPT code on the claim.

There are several very informative fact sheets that you may find helpful out there. CodingIntel published one (here). You may need to create a login (free) to access it. I have also included our internal resources for your review below.

Shared/Split Resource Sheets:

• • Transmittal 11288 Shared Visit Changes
  • Shared Prolonged Services (currently being updated)
  • Shared Critical Care Services
  • Shared Facility Setting E/M Services
  • Quick Tips Sheet
  • IM At-a-Glance News Blast
  • MSHBC (Internal) Shared/Split Infographic

Article revised 09/12/2023 with AAPC substantive portion language.

Contact for more information:

[email protected] or [email protected]. You can also reach out to your departmental compliance liaison listed under our “Meet the Team” tab.

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