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New CMS rule on split/shared encounters set to be delayed until 2024

Insight Article - July 8, 2022

Medicare Payment Policies

Staffing Models

Coding & Documentation

Billing & Collections

Amanda Rumpke MSN, APRN-CNP
The Centers for Medicare & Medicaid Services (CMS) plans to delay implementation of the narrowed definition of “substantive” as it relates to split or shared encounters, from January 2023 to January 2024.

The proposed delay was included in the July 7 release of the 2023 Medicare Physician Fee Schedule (MPFS) proposed rule.1 This comes on the heels of a letter from nearly 20 physicians’ organizations penned in March urging CMS to reverse course on their final rule, which would require the billing provider to spend more than 50% of time on the facility-based split/shared patient encounter. The letter cited concerns regarding the perceived negative implications for rule-driven deviation from a collaborative care delivery model, patient experience and a knowledge gap regarding physician and organizational impact of rule implementation.2

As organizations grapple with this newest development from CMS, they must also balance their approach with other regulatory and industry shifts. To date, 27 states have adopted full practice authority for nurse practitioners (NPs).3 Additionally, a growing body of evidence exists to support that advanced practice providers (APPs) functioning in the hospital setting improve outcomes, patient experience and readmission.4,5

As providers wait for additional guidance from CMS over who will bill for shared patient services, organizations have a renewed opportunity to answer important questions for their physicians, APPs and patients.
  • How frequently do physician and APP teams share services in our organization?
  • How will a 2024 change impact these teams from a clinical workflow, provider burnout and compensation perspective?
  • How should medical groups and other healthcare organizations that have already adopted the previously published 2023 final rule regarding split/shared visit billing move forward between now and 2024? 
  • As the healthcare landscape continues to evolve, and APPs have a more prominent role in care delivery, how do can we ensure patients get the care they need from the right provider at the right time?

Learn more


  1. CMS. “Calendar Year (CY) 2023 Medicare Physician Fee Schedule Proposed Rule.” Fact sheet. July 7, 2022. Available from:
  2. American College of Chest Physicians. “CMS urged to rescind APP split/shared policy.” April 11, 2022. Available from:
  3. AANP. “State Practice Environment.” Available from:
  4. Aiken LH, Sloane DM, Brom HM, Todd BA, Barnes H, Cimiotti JP, Cunningham RS, McHugh MD. “Value of nurse practitioner inpatient hospital staffing.” Medical Care, 59(10), 857–863. Available from:
  5. Kleinpell RM, Grabenkort W, Kapu AN, Constantine R, Sicoutris C. “Nurse practitioners and physician assistants in acute and critical care.” Critical Care Medicine, 47(10), 1442–1449. Available from:

About the Author

Amanda Rumpke
Amanda Rumpke MSN, APRN-CNP
System Director, Advanced Practice Clinicians Pulmonary and Critical Care Consultants of Fairfield


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