For 2020 "transitional year", shared visits can be billed by either:
1) the clinician that spent > 50% of the time OR
2) the clinician that provided the "substantive" portion of the visit. CMS is allowing us to decide whether history, exam or MDM was the "substantive" portion. Whichever element you are deciding is the substantive portion, the billing provider's documentation alone must meet the level.
That option 2 above is what is different in 2022. In 2023 the billing provider will only be determined by > 50% of time.
For this year, I did not provide much education to my providers other than changes are coming. I am having them document pretty much the same way they had prior. It simply means there may be some visits where prior I could have billed under the MD, but now need to bill under the NPP. Once we get closer to 2023, I will start reminding them that all providers need to document the time spent so I will be able to determine who the billing provider is.
The reasoning for this change is that there are many, many, many providers where the NPP is really providing 95% of the service, and the physician pokes their head in the patient room for 2 minutes and signs off. CMS is simply stating those visits are billable, but not billable under the physician.