Overview
A split/shared visit is a facility-based Evaluation and Management (E/M) service where a physician and a Non-Physician Practitioner (NPP) — nurse practitioner (NP), physician assistant (PA), or clinical nurse specialist (CNS) — both personally perform substantive portions of the visit on the same date of service. The billing entity (physician or NPP) is determined by who performed the substantive portion. Medicare redefined substantive portion effective 2022 with subsequent refinements.
The 2022+ Medicare definition: substantive portion of a split/shared visit is based on time — the clinician who personally performs more than 50% of the total time associated with the visit is the billing provider. Medical decision making (MDM) can alternatively serve as the substantive criterion with specific rules, but time is the primary framework. Prior to 2022, substantive portion was based on history, exam, or MDM — a more subjective framework.
Split/shared visits are permitted in facility settings: hospital inpatient, hospital outpatient, emergency department, observation, skilled nursing facility. They are NOT permitted in office-based settings (place of service 11). In office settings, if both a physician and NPP see a patient, the billing is either 100% to the clinician who documented the visit or under "incident to" rules with stricter supervision requirements.
Billing dynamics matter financially. NPP services to Medicare under NPP's own NPI reimburse at 85% of physician fee schedule for most E/M. Physician services reimburse at 100%. Split/shared visits where the physician is the substantive clinician can bill at 100%, capturing the physician rate for the service. Incorrect identification of substantive clinician produces billing violations.
Documentation requirements: both clinicians must document their personal work — history, exam, MDM, time. The substantive-portion determination must be documentable: total visit time recorded, clinician-specific time recorded, or MDM attribution if using that criterion. The billing clinician's signature and note must reflect their participation and the substantive portion.
For RCM, split/shared billing requires specific workflow infrastructure. EHRs should capture clinician-specific time for each visit when split/shared applies. Providers and NPPs must document their own portions separately. Billing compliance audits review split/shared claims to ensure proper substantive determination. Improper billing (NPP did the work, physician signed, billed at 100%) is a common audit finding with significant recovery exposure.
Evolving payer policy. Medicare split/shared rules have been refined through CMS rulemaking cycles. Commercial payer coverage varies; some follow Medicare closely, others have different rules. Medicaid policies differ by state. State scope-of-practice laws affect NPP billing authority and split/shared eligibility.
Specialty practice patterns matter. Hospital medicine (hospitalists) commonly uses split/shared billing with NPP support; proper substantive determination is ongoing workflow focus. Emergency medicine uses split/shared where physician collaboration with physician assistants structures care. Critical care has specific rules; some split/shared scenarios interact with critical care time-based billing rules.
Compliance risks are non-trivial. Office of Inspector General (OIG) work plans have included split/shared billing reviews. Enforcement actions for improperly-billed split/shared claims have produced substantial recoveries. Provider and NPP education, documentation templates, and audit sampling are standard compliance practices.
Industry benchmark
CMS Split (or Shared) E/M Visits Final Rule (2021, revised 2022 and 2024). CMS Internet-Only Manual 100-04 Chapter 12. Medicare Program Integrity Manual.
Worked example
A hospitalist and a PA jointly manage an inpatient admission. PA performs initial comprehensive history and examination (45 minutes). Physician performs MDM, assessment, and treatment planning (25 minutes). Total visit time 70 minutes. PA performed more than 50% (substantive portion). Correct billing: PA's NPI, E/M code at 85% of MPFS. If physician had instead performed 40 minutes and PA 30 minutes, physician would be substantive clinician and billing under physician's NPI at 100% of MPFS.
Frequently asked questions — Split/Shared Visit
Who can participate in a split/shared visit?
A physician and a non-physician practitioner (NP, PA, CNS) from the same group/specialty. Both must personally perform substantive portions of the visit on the same date of service in a facility setting. Office-based split/shared is not permitted.
How is substantive portion determined?
Per 2022+ Medicare rules, based on time — the clinician performing more than 50% of total visit time is substantive. MDM can alternatively serve as criterion under specific rules. Prior to 2022, substantive was based on history, exam, or MDM subjectively. Clear documentation of time is central.
Does split/shared billing apply in office settings?
No. Office-based visits (POS 11) use either full billing under the performing clinician or 'incident to' billing under stricter physician supervision rules. Split/shared is specifically a facility-setting construct (inpatient, outpatient, ED, observation, SNF).
What are the billing implications?
NPP services bill at 85% of MPFS. Physician services bill at 100%. Correct substantive determination matters financially and compliance-wise. Improper billing (NPP performed visit, physician signed, billed at 100%) is a common audit finding with substantial recovery exposure.
Disclaimer
This glossary entry is operational reference for revenue-cycle and medical-billing professionals. It is not legal, clinical, or contractual advice. Industry benchmarks cite named public sources where available; always verify against the current guidance from the authority body before relying on a number in a contract, policy, or compliance filing.