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2022 Physician Fee Schedule Final Rule: Highlights

Do you know that CMS is making significant changes to split/share and critical care services in 2022? Are your providers aware of the changes? Are they prepared to modify the documentation of these services? Are your coders prepared to report the required modifier?

On November 2, 2021, CMS released the 2022 Physician Fee Schedule Final Rule. Significant changes were made to both split/share and critical care guidelines.

All changes begin January 1, 2022.

For Split/Share services, the following is to be implemented:

  • Shared services are E/M services performed jointly between a physician and a non-physician practitioner (NPP).
  • CMS is requiring that the shared visit be reported under the provider number of the physician or non-physician practitioner who has performed a substantive portion of the visit.
  • They are defining a substantive portion of the service as the practitioner who performed more than 50% of the time of the visit, or the practitioner who performed and documented in its entirety either the history, exam, or medical decision-making portion of the note. “We are clarifying that when one of the three key components is used as the substantive portion in 2022, the practitioner who bills the visit must perform that component in its entirety in order to bill. For example, if history is used as the substantive portion and both practitioners take part of the history, the billing practitioner must perform the level of history required to select the visit level billed.”.
  • Critical care may be billed as a shared visit between a physician and NPP but must be reported by the practitioner who provides >50% of the time.
  • Always append modifier FS (Split (or shared) Evaluation and Management service.) Use this for shared or split services between a physician and non-physician practitioner, including critical care.

For critical care services, the following changes have been made:

  • CMS will now allow physicians/NPPs of different specialties to both provide critical care during the same time period. Their withdrawn manual section only allowed one practitioner to be paid for critical care at any one time.
  • CMS will continue to allow an E/M service to be performed on the same day as critical care, if the E/M service occurred before the patient was critically ill, the patient later became ill later on the same calendar day. They removed the restriction that did not allow an ED visit and critical care to be billed on the same day by the same physician.
  • CMS will continue to allow surgeons to bill post-operative critical care that is unrelated to the surgery that was performed.
  • Always append modifier FT (Unrelated Evaluation and Management (E/M) visit during a postoperative period, or on the same day as a procedure or another e/m visit. (report when an E/M visit is furnished within the global period but is unrelated, or when one or more additional E/M visits furnished on the same day are unrelated.) Use this for critical care performed by a surgeon during a global period. The critical care must be unrelated to the procedure/surgery done.

Contact Us

To learn more about how Blue & Co. can help your organization with opportunities surrounding the 2022 Physician Fee Schedule Final Rule, reach out to your local Blue & Co. advisor or contact Beverly Strube or Maddie Gookins.

Beverly Strube, Senior Physician Coding Consultant

Maddie Gookins, Director

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