In 2024, CPT® expanded its definition of split/shared services, CMS updated their requirements. Neither CMS nor CPT® made changes to this policy in 2025 or 2026.

• Medicare requires that both practitioners are enrolled in Medicare, and both have E/M in their scope of practice.
• CPT® expanded its definition of split/shared services in 2024. The service is reported by the practitioner who performed the substantive portion of the visit. 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 also will allow the substantive portion to be determined based on the practitioner who spent more than 50% of the time orthe practitioner who performs the medical decision making (MDM).
• 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.” This was language in the Final Rule in 2024, but is not in their manual.
• Services may include both face-to-face and non-face-to-face activities. CMS says one of the practitioners needs to have a face-to-face visit with the patient.
• Services billed using the physician’s NPI are paid at a higher rate than those billed by a non-physician practitioner and so reporting them compliantly is important.
• For Medicare, shared services may only be done in a facility setting; shared services may not be performed in place of service 11, office, 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® Many groups use the term Advance Practice Practitioners.