Lexology November 10, 2021
On November 2, 2021, the Centers for Medicare & Medicaid Services (CMS) issued the calendar year (CY) 2022 Medicare Physician Fee Schedule (MPFS) final rule which, among other policy and regulatory changes, finalized regulations codifying CMS requirements for billing for “split (or shared)” evaluation and management (E/M) visits under the MPFS. Split (or shared) visits are E/M visits provided in part by both physician and non-physician practitioners (NPPs) and are now defined at 42 CFR § 415.140. NPPs generally include nurse practitioners, physician assistants and clinical nurse specialists, and are also known outside of the Medicare program by other names, such as advanced practice practitioners. The finalized regulations generally reflect prior CMS guidance for billing “split/shared” visits, but also incorporates...