Coding Report: Split/Shared Visit Guideline Update

Happy New Year!

You may be planning on hitting the gym a little more frequently, or maybe you are hoping to lose a few pounds. Maybe 2025 is the year you will tackle that junk drawer and get organized! Jan. 1 also brings the Current Procedural Terminology ®(CPT) update.

For 2025, there are 270 new CPT codes; 112 codes have been deleted, and 38 codes have been revised. 

In the months to come, we will be examining some of the changes in this update, the first being the E&M (Evaluation and Management) guidelines regarding split/shared visits. As a quick refresher, a split or shared service is an E&M visit in the facility setting that is performed in part by both a physician and a non-physician practitioner (NPP) who are both in the same group, in accordance with applicable law and regulations, such that the service could be billed by either the physician or the NPP if only one of them furnished it independently.

Additionally, the Centers for Medicare & Medicaid Services (CMS) defines a split/shared visit as one that is performed by both a physician and an NPP who bill under the same tax identification number (TIN) and are in the same specialty group. 

Previous considerations have been focused on the substantive portion of the visit, and which practitioner performs it. This substantive portion can be more than half of the total time spent by the physician and NPP, or a substantive part of the medical decision-making (as defined by CPT, under the purview of the American Medical Association) for those visits involving medical decision making (MDM). 

The 2025 Guideline update offers additional details and interpretation regarding the “substantive portion” of the E&M service; the first set pertains to time as the driver of the service code. The professional spending the majority of the total time on the date of the encounter would report the service for reimbursement. 

The second involves the medical decision-making (MDM) as the driver of the service code. The individual who approves the care plan for the problems addressed and takes responsibility related to management of risk is the person providing the substantive portion of the visit, under these criteria. If date is used to assign the level of MDM, only the person who performs an independent interpretation or discussion of management or test interpretation may use those categories. 

It is interesting to note that no modifiers are specified here. Previously, these split/shared visits were reported with the FS modifier. Remember, these updates took effect as of Jan. 1, 2025. Be sure to review the update in its entirely and share the changes with your providers and team. 

Here’s hoping you have a happy, healthy 2025! 

Programming note:

Listen to Christine Geiger today when she joins the live edition of Talk Ten Tuesday and reports on the latest coding news.