The CAP joined with more than 45 other medical groups to urge the Centers for Medicare and Medicaid Services (CMS) to rescind a rule on billing for split or shared visits when elements are performed by both a physician and a qualified health care professional. The CAP advocates to ensure adequate representation for coverage and reimbursement issues facing pathologists in the regulatory landscape.

Under the 2022 Medicare Physician Fee Schedule, beginning in 2023, only the physician or the qualified health professional who performs more than 50% of the time of the total visit can bill the split or shared visit. According to a March 29 letter the groups sent CMS Administrator Chiquita Brooks-LaSure, the policy would drastically disrupt team-based care and interfere with the way care is delivered in the facility setting.

The letter notes that the organizations support physician-led, team-based care, and patients benefit from the collaboration of physicians and qualified health professionals who care for patients in hospitals, skilled nursing facilities and other facilities, where they work hand-in-hand. Billing based on who performs more than 50% of the total time of the visit will disincentivize the continuation of these care relationships, the organizations argue. They added there is significant variability in how much time it takes to perform elements of the visit based on the level of training and expertise of the physician and the qualified health professional.

“CMS should not move forward with this policy and, instead, we urge CMS to propose an alternative policy in the CY 2023 Medicare Physician Payment Schedule proposed rule that allows physicians or QHPs to bill split or share visits based on time or medical decision-making,” write the groups. “Doing so will allow CMS to seek public comment from physicians and QHPs to ensure that the revised policy does not have any unintended consequences for team-based care and patients.”

The CAP will continue to follow this issue and keep members updated in future advocacy updates.