Academy Advocates for Changes to 2023 Split or Shared Services Policy

Members & Publications

May 5, 2022

In anticipation of changes to the current split or shared services policy, AAPM&R has submitted comments to the Centers for Medicare & Medicaid Services (CMS) highlighting concerns with the changes expected to go into effect January 1, 2023.

In the 2022 Medicare Physician Fee Schedule, CMS announced that it would change its split or shared services policy effective 2023 to require that shared services be reported by the provider who provides more than half of the time of the service. With billing being tied only to time, rather than medical decision making, the new policy runs the risk of negatively impacting physicians who may spend less time with the patient but shoulder more of the cognitive workload.  AAPM&R strongly disagrees with this policy and seeks to encourage CMS to revise the policy to allow medical decision making to be a deciding factor in split or shared services billing.

In addition to submitting an Academy letter, AAPM&R has signed on to similar joint statements submitted to CMS by the American College of Physicians and the American Medical Association.  We anticipate additional advocacy on this issue will be necessary throughout 2022.  


Legislation Introduced to Alleviate Impact of Conversion Factor Cut for 2021

Nov 09, 2020

Last month, two bills were introduced in the House proposing solutions to the estimated 10.6% Physician Fee Schedule conversion factor cut expected to go into effect January 1, 2021.  The bills offer some relief to the cut, but do not reflect a comprehensive or long-term solution.  AAPM&R has therefore chosen to remain neutral regarding these bills. 

Your Academy continues to advocate for a permanent solution to the conversion factor cut while maintaining the important payment increases to office and outpatient evaluation and management services.