Healthcare Consultancy HSG Urges Proactive Intervention to Mitigate Adverse Consequences from 2022 CMS Split/Shared Visit Rules

Updated on March 1, 2022

HSG, a national healthcare consultancy that supports health systems in building differentiated health system strategies, has issued a guide for hospitals and healthcare systems as they encounter additional disruption to wRVU credit, physician and APP compensation, and overall revenue as a result of the 2022 CMS Split/Shared Visit Rules.  The guide, authored by Terrence McWilliams, MD, FAAFP, Director and Chief Clinical Consultant at HSG, “The 2022 CMS Split/Shared Visit Rules and the Anticipated Impacts,” is available for download at

Many executives read reviews of the 2022 Medicare Physician Fee Schedule (MPFS) Final Rule and focused on the additional 3.75% decrease in the Medicare conversion factor and the impact that determination would have on revenues. The 2022 MPFS Final Rule could generate a similarly devastating disruption of wRVU credit, physician and APP compensation, and organizational revenue for hospital-generated professional services in many specialties.

The 2022 MPFS Final Rule defines a split (or shared) visit as “an E/M visit in a facility setting that is performed in part by a Physician and a Nonphysician Practitioner who are in the same group.” The 2022 MPFS Final Rule also clarified that the Split/Shared Visit scenario does not apply to the office setting. The Rule requires that the encounter be billed under the provider who performed “the substantive portion” of the encounter.

“The changes to the Split/Shared Visit Rules create several significant consequences for employed provider networks. If the Advanced Practice Provider (APP) becomes the designated ‘Billing Provider’ by performing the ‘substantive portion’ of the encounter based on the total time spent, the APP would, by default, be awarded all of the wRVU credit for these encounters. The immediate impact of this change is that the involved physicians’ wRVU credit would plummet – with serious consequences in production-based compensation models,” said Dr. McWilliams. 

In addition to the modified definition and specificity of the billing provider for the “substantive portion” of the visit, changes have also been made to claims submissions to permit for identification and tracking of these encounters.  The definition of encounters has also been broadly expanded from the previous rule. 

Organizations need to be aware of the presence, and potential impact of the new CMS Split/Shared Visit Requirements and proactively intervene to mitigate adverse consequences. With every challenge comes opportunity – and this challenge is no exception. Hospital and health system leaders can work with HSG for analyses or assistance with any new issues presented due to the new 2022 CMS Split/Shared Visit Rule, particularly regarding the impact on physician and APP compensation models. Find out more at the website

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