CMS is proposing to allow split/shared visit billing for critical care because it believes the practice of medicine has evolved towards a more team-based approach to care, with greater integration of physicians and APPs into the clinical practice, particularly when care is furnished by clinicians in the same group in the facility setting. Since critical care is a time-based service, CMS requires practitioners to document in the medical record the total time that critical care services were provided and identify the provider who performed the majority of the patient-care time. The physician that provides more than 50 percent of the total time should be the one to report the critical-care code.

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Look for updated FAQ sets in the coming weeks both on the resource-based relative value scale equation and on split or shared services at acep.org/reimbursement-FAQs.

Telehealth

While no new codes were permanently added to the Medicare Telehealth Services list, the new rule finalizes a new process for adding, removing or otherwise changing codes on the list, and creates differential payment based on the place of service.

In this rule, CMS decided to maintain all five ED E/M codes (99281 to 99285). These codes are listed as provisional in Table 11 of the 2024 PFS Final Rule, meaning that they may be reported via telehealth at least through the end of 2024.

Additionally, some observation codes on the list of approved telehealth services are included at least through the end of calendar year 2024:

• Initial Hospital Inpatient or Observation Care—99221 to 99223
• Hospital Inpatient or Observation Care Services, Same Day Admission and Discharge—99234 to 99236
• Discharge from Hospital Inpatient or Observation Care—99238 to 99239

Additional Resources

Resources for these and other topics can be found on the reimbursement section of the ACEP website. Mr. McKenzie can also answer ACEP members’ specific, individual questions at dmckenzie@acep.org.

Dr. Granovsky is President of LogixHealth, an ED coding and billing company, and currently serves as the Course Director of ACEP’s annual Coding and Reimbursement Conferences.

Mr. McKenzie is the reimbursement director at ACEP.