What physicians should know about chronic care management changes

Q: Are there other services that we can’t bill if we are billing chronic care services?

A: Chronic care management services (99490) cannot be billed during the same service period as: 

99495-99496 Transitional Care Management Services 

G0181-G0182 Home Health Care Supervision/Hospice Care Supervision), or 

90951-90970 Certain End-Stage Renal Disease services. 

Look for some possible changes in 2017 that could help reimbursement for Chronic Care Management (99490) and Complex Chronic Care Management (99487 and 99489), including:

No initiating visit for established patients.

Under current billing rules, a provider must formally initiate the CCM service during an E/M visit, annual wellness visit (AWV) or initial preventive physical exam (IPPE). CMS has proposed that this wouldn’t apply to established patients that the physician/practitioner has seen within the past 12 months. 

Temporary code GPPP7. CMS proposes a new add-on code that gives providers an additional payment opportunity when conducting an initiating visit for new patients. 

Separate beneficiary consent form no longer required. Instead, CMS suggests that providers can document that they shared information about the scope of CCM services “and note whether the beneficiary accepted or declined CCM.”

Next: No more standards for sharing clinical summaries

No separate authorization for sharing information electronically.

This requirement could be taken out.

All-day access to electronic care plan no longer required.  Under current billing rules, providers furnishing CCM services must have access to the electronic care plan on a 24/7 basis. CMS has proposed instead that a provider must be available to a patient who’s receiving CCM services on a round-the-clock basis for “urgent” care needs.

Sharing of care plan must be “timely” instead of on a 24/7 basis. CMS seems to have realized that 24/7 access isn’t feasible.

No more standards for sharing clinical summaries.

To get paid for CCM under current rules, providers must use certified electronic health record technology (CEHRT) to produce and share a clinical summary.  The revised approach that CMS proposes would be to simply require providers to create and exchange this information.

Care plan summary can go to a patient or caregiver - in the format a provider deems appropriate. CMS has proposed backing off of the electronic health record (EHR) as the way the information needs to be given to a patient or caregiver.

Q: What place of service (POS) should be reported on the physician claim? 

A: Practitioners must report the POS for the billing location (i.e., where the billing practitioner would furnish a face-to-face office visit with the patient). Accordingly, practitioners who furnish CCM in the hospital outpatient setting, including provider-based locations, must report the appropriate place of service for the hospital outpatient setting). Payment for CCM furnished and billed by a practitioner in a facility setting will trigger PFS payment at the facility rate.