There has been much discussion and controversy over the new CMS position on billing for split/shared services in facility settings.

As originally proposed, and starting in January 2022, if the service was shared among providers (such as physicians and physician assistants), the provider who performed the substantive portion of the visit would be the provider

Under the Federal Ethics in Patient Referrals Act (more commonly known as “Stark”), if a physician[1] has a financial relationship with an entity, the physician may not refer patients to the entity for medical services payable by Medicare unless the financial relationship complies with the Stark safe harbors.  Thus, entities that lease or sublease

In MLN Matters article MM 12159, CMS has published summaries of the following:

  • Updates to payment policies and Medicare payment rates for services provided by physicians and non-physician practitioners (NPP)
  • Updates to Medicare telehealth services and telehealth originating site facility fee payment amounts
  • Billing for a physician assistant (PA) services

 

CY 2021 Physician Fee Schedule Update

On December 27, 2020, the Consolidated Appropriations Act modified the Calendar Year (CY) 2021 Medicare Physician Fee Schedule (MPFS):

  • Provided a 3.75% increase in MPFS payments for CY 2021
  • Suspended the 2% payment adjustment (sequestration) through March 31, 2021
  • Reinstated the 1.0 floor on the work Geographic Practice Cost