In 2024, CPT® expanded its definition of split/shared services, CMS updated their requirements. Neither CMS nor CPT made changes tot his policy for 2025.

• CPT® expanded its definition of split/shared services in 2024, stating that the substantive portion can be determined by the practitioner who spent more than 50% of the time, or who made or approved the medical decision making.
• CMS will allow the substantive portion to be determined based on the practitioner who spent more than 50% of the time or the practitioner who performs the medical decision making (MDM). They have removed allowing documenting history or exam in its entirety, since these are not current CPT® concepts.
• CMS continues to say that this is a delay until 2025 when only time can be used, but this is the third delay by my count.
• CMS says when the work is shared, “we expect that whoever performs the MDM and subsequently bills the visit would appropriately document the MDM in the medical record to support billing of the visit.”
• Services may include both face-to-face and non-face-to-face activities.
• Services billed using the physician’s NPI are paid at a higher rate than those billed by a non-physician practitioner.
• For Medicare, shared services may only be done in a facility setting; shared services may not be performed in place of service 11 for Medicare patients. CMS notes that there is an incident to benefit for the non-facility setting.
• CPT® is silent about location.
• Medicare requires HCPCS modifier FS- Split (or shared) Evaluation and Management service to identify shared services.
• Terminology: CPT® uses “other qualified health care professionals” and CMS uses “non-physician practitioners” to describe APRNs and PAs who have E/M in their scope of practice in the E/M section of the CPT® book.