Billing for split (shared) E/M services

A split or shared visit is an evaluation and management (E/M) visit that meets all the following criteria:

  • Performed in a facility setting AND
  • Performed in part by both a physician and a non-physician practitioner (NPP) AND
  • Physician and NPP are part of the same group practice.

Split or shared services can be reported for new patients, established patients, initial services or subsequent services.

Payment is made to the practitioner who performs the substantive portion (see below) of the visit.

Billing tips for split or shared E/M services

  • Don’t submit separate claims. Only bill for the practitioner who provided the most substantive portion of the service (see below).
  • Meet E/M coding requirements for billing at the specified level of service (see documentation requirements below under “Requirements to bill split / shared services”).
  • Rely on the substantive portion of the service to drive the billing provider. Reimbursement for services billed under a physician or non-physician practitioner may differ depending on contracted fees. However, this shouldn’t drive the billing provider decision.
  • Select E/M CPT codes based on MDM or time based on new E/M CPT guidelines. However, this may not drive which provider performed the substantive portion of the service as history and exam elements are considered.
  • Services performed within a global period of 0, 10 or 90 days are still applicable.

Bill split/shared services with modifier FS

Append modifier FS, Split or shared E/M visit, to the E/M service billed under the practitioner providing the substantive portion of the service. This can be either the physician or NPP.

Requirements to bill split/shared services

To bill these services, the following must exist:

Place of service

E/M services can be allowed as a split or shared service in a facility setting which includes inpatient, outpatient, emergency room, observation services and critical care services.

Group practice

Both the physician and NPP, each with their own assigned NPI, must be part of the same practice group.

  • When entities have separate tax identification numbers, payment arrangements are defined by the group agreement as Priority Health will send payment to the billing practitioner. (Follows Medicare guidelines.)
  • Each practitioner must be able to show how they’re a group when performing services under a split or shared billing arrangement. (Follows CMS guidelines.)

Substantive portion of E/M service

The practitioner providing the most substantive portion can bill for the E/M service. Select the E/M level based on documentation prepared by both the physician and NPP.

The documentation must support and define which practitioner is performing the substantive portion, including:

  • E/M components, including history, exam, medical decision making (MDM) and time (if applicable, see below for examples)
  • Elements performed by both practitioners
  • Face-to-face services provided by at least one of the practitioners (doesn’t have to be the billing provider)

According to the Centers for Medicare & Medicaid Services (CMS) Correct Billing of Split (Shared) Services, below are examples of elements for qualifying time:

  • Preparing to see the patient (i.e., review of tests)
  • Obtaining and/or reviewing separately obtained history
  • Performing a medically necessary exam or evaluation
  • Counseling and educating patient / family / caregiver
  • Ordering medications, tests or procedures
  • Referring and communicating with other health care professionals (when not separately reported*)
  • Documenting clinical information in the electronic or other health record
  • Independently interpreting results (not separately reported*) and communicating results to patient / family / caregiver
  • Care coordination (not separately reported*)

*”Not separately reported” means neither practitioner submits a separate charge for the activity. When submitting a separate charge, carve out the time spent from the remainder of the E/M service.

Additional resources

Correct Billing of Split (Shared) Services (

Medicare Claims Processing Manual (