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    March 29, 2022 

    The Honorable Chiquita Brooks-LaSure
    Centers for Medicare & Medicaid Services
    U.S. Department of Health and Human Services
    Hubert H. Humphrey Building, Room 445–G
    200 Independence Avenue, SW
    Washington, DC 20201

    Dear Administrator Brooks-LaSure:

    On behalf of our members, the American Medical Association (AMA) and the undersigned national medical specialty societies urge the Centers for Medicare & Medicaid Services (CMS) to rescind the CY 2022 Medicare Physician Payment Schedule final rule1 regarding who should bill for split or shared visits when elements of the visit are performed by both a physician and a qualified healthcare professional (QHP), and revise the rule after providing another opportunity for public comment on this policy. Beginning in 2023, only the physician or QHP who performs more than 50 percent of the time of the total visit can bill the split or shared visit. This policy would drastically disrupt team-based care and interfere with the way care is delivered in the facility setting. CMS should not move forward with this policy and, instead, we urge CMS to propose an alternative policy in the CY 2023 Medicare Physician Payment Schedule proposed rule that allows physicians or QHPs to bill split or shared visits based on time or medical decision-making. Doing so will allow CMS to seek public comment from physicians and QHPs to ensure that the revised policy does not have any unintended consequences for team-based care and patients.


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