Significant Split/Shared Billing Win for Hospitalists in CY2024 Physician Fee Schedule Final Rule

On Friday, November 3, the Centers for Medicare and Medicaid Services (CMS) released the CY2024 Physician Fee Schedule Final Rule, which contains a significant WIN for hospitalists—changes to the split (or shared) billing policy. CMS finalized either time or medical decision making (MDM) can be used to determine the billing provider for split (or shared) visits beginning in 2024 and beyond. There will be no more delays or threats of an exclusively time-based policy.

Why will this benefit hospitalists?

This newly finalized policy will allow for the continued use of MDM, in line with current policies for split or shared billing, and better accounts for physician involvement in split (or shared) visits.

A time-based policy is not reflective of team-based care. Time can be challenging to track in the inpatient setting. Care is often non-continuous throughout the day and tracking time under a strict time-based policy would have been extremely laborious and difficult to do accurately.

What was SHM’s role in securing this policy win?

SHM was a leading voice on this issue, vocally opposing CMS’ previously finalized policy, which would have utilized time exclusively to determine the billing provider. To represent the concerns of our members, SHM submitted numerous comments to CMS, attended briefings, collaborated with other specialty societies and the Current Procedural Terminology (CPT) editorial panel, and had dedicated meetings with CMS officials to highlight the detrimental impact of the time-based policy on hospital medicine teams and how it adds unnecessary administrative burdens. The newly finalized change preserves the use of MDM to help determine which clinician should bill for these split or shared visits.