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  • Writer's pictureRYAN FERGUSON

CMS Proposes Physician E/M Coding Changes and More

Updated: Oct 20, 2023

  1. Proposing a definition of split (or shared) E/M visits

  2. Identifying who the appropriate practitioner to bill for the split E/M visit is

  3. Identifying which E/M codes can be reported as split visits

  4. Requires the reporting of a modifier for split visits

  5. Outlining how to document this in the medical record Additional proposals were made to Critical Care Services, including:

  6. Proposing preferred language for the definition of critical care visits and bundled services

  7. Allowing critical care services to be furnished concurrently to the same patient on the same day by more than one practitioner representing more than one specialty, and that critical care services can be furnished as split visits.

  8. Proposing restrictions around what other services can be billed alongside critical care services. Further clarity was proposed around when teaching physicians are present within the primary care exception when determining the appropriate E/M visit level. Under the primary care exception, medical decisions making (MDM) would be used to select the visit level. Other changes to Therapy Services, Physician Assistant Services, Medical Nutrition Therapy (MNT) and Related Services, Provider Enrollment, and the Appropriate Use Criteria have been proposed. MCC’s experts scrub these rules and prepare for changes that would take effect in the coming years (if the proposals are finalized) to ensure compliance from the point of care through claims processing.  Contact our team at to find out how you can utilize RemitOneTM to stay on top of the never-ending changes to coding, coverage, payment, and CMS regulations. To see more about MCC and RemitOne, visit our documentary segment that aired on CNBC here:



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