In October, we posted about Medicare’s proposals for drastic improvements to Chronic Care Management (CCM) and other reimbursable programs like Remote Physiologic Monitoring (RPM), starting Jan. 2020.

Good news: These changes were just finalized with the release of Medicare’s 2020 Physician Fee Schedule.

Below, we explore the most impactful changes that practice leaders need to know.

Table of Contents:

1. Transitional Care Management (TCM)
a. Fee increase
b. Now allows other care management to be concurrently billed with TCM

2. CCM
a. New code for each additional 20 minutes of care management beyond 20 minutes per month
b. Complex CCM removes requirement for ‘substantial care plan revision’

3. Remote Physiologic Monitoring (RPM)
a. New code for each additional 20 minutes of care management beyond 20 minutes per month
b. Allows off-site care managers

4. New “Principal Care Management” (PCM) codes for patients with 1 ‘serious chronic condition’

1. TCM (Transitional Care Management) fee increase

As discussed in our last post, Medicare found that i) TCM utilization is still low compared to the number of Medicare discharges and that ii) TCM services reduced readmission rates, lowered mortality, and decreased health care costs.

To increase clinicians’ use of this valuable care program, Medicare is increasing reimbursements for TCM codes by as much as 12% and allowing care management codes like CCM (ex: CPT99490) to be concurrently billed with TCM: “we are finalizing… to allow concurrent billing of the care management codes currently restricted from being billed with TCM. This includes allowing concurrent billing of TCM with the 14 codes specified in Table 20, as well as CPT codes 99490 and 99491” (page 397)

2. Chronic Care Management (CCM)

Medicare again referenced data showing cost savings from CCM and reiterated their intention to responsibly expand CCM to appropriate patients. The two key proposals discussed in our last post were implemented. That is, additional care management time beyond 20 minutes can be reimbursed, and, Complex CCM no longer requires a significant care plan change. However, some minor coding changes were made in the final ruling:

a. The finalized code for each additional 20 minutes of care, G2058, will take the place of the proposed code “GCCC2”, and be billable on top of CPT 99490

• Reimburses “each additional 20 minutes” of needed non-face-to-face follow-up care beyond the first 20 minutes per month.
• 0.54 RVU
• G2058 can be billed concurrent to 99490, up to 2 times for the same patient per month
• Medicare: “we are finalizing GCCC2 (the add-on for non-complex CCM clinical staff time), henceforth referred to as G2058, because this code addresses what we believe is an important gap in the current code set” (page 404)

b. Complex CCM codes no longer require “substantial care plan revision”. This requirement limited care for many folks requiring 60+ minutes of care coordination where there may not be a ‘substantial care plan revision’ as defined by CMS. To prevent overuse, Medicare is keeping the “moderate or complex medical decision making” requirement in place.

3.  Remote Physiologic Monitoring (RPM) has a new 20 minute code and allows remote care managers

Medicare finalized the 2 key changes for Remote Physiologic Monitoring (a set of ~$60-$120 reimbursements, per patient per month, for monitoring+managing vitals like blood sugar/pressure).

First, Medicare finalized a new add-on code, CPT 99458, which pays 0.61 RVUs for an additional 20 minutes of clinical care management time relating to vitals monitoring. This 99458 code is in addition to the existing CPT 99457 code for the first 20 minutes.

Second, Medicare now allows general supervision for the CPT 99457 and 99458 codes, meaning remote care teams may provide this care. Specifically, they ”designate both CPT code 99457 and CPT code 99458 [to be] care management codes as defined in § 410.26(b)(5) of our regulations.” (page 431) This means that off-site care managers like CircleLink’s 100% RNs can provide the “Remote physiologic monitoring treatment management services”, whereas in 2019 the clinical staff providing services needs to be on-site in the same facility as the supervising provider/doctor.

4. New “Principal Care Management” for patients with 1 ‘serious chronic condition’

Medicare finalized 2 codes (below) relating to “Principal Care Management” to cover patients with a single serious chronic condition. This enables care management for patients who don’t qualify for CCM’s 2-condition requirement.

• G2064 (1.45 RVUs for 30 mins of Dr. time)
• G2065 (0.61 RVUs for 30 mins of clinical staff time)

However, it should be noted that G2065 requires 30 minutes of staff time while paying the same RVU as CCM pays for 20 minutes.

These codes require 1 condition for which a patient has received care for 3-12 months, which puts patient at risk for hospitalization, or has resulted in a recent hospitalization.

While a practitioner (Primary Care or Specialist) may bill PCM concurrent with RPM, they may not bill PCM with other care management codes (e.g., CCM) for the same patient/month.

Finally, while PCM’s requirements mirror CCM’s, there are two key differences:

• Care Plan: PCM requires a “disease-specific” care plan vs. CCM’s comprehensive care plan
• Documentation: PCM requires that communication/care coordination “between all practitioners furnishing care to the beneficiary… be documented by the practitioner billing for PCM in the patient’s medical record.” (page 420)

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Is your practice prepared to take advantage of these adjustments to CCM, RPM and other care management programs? CircleLink demystifies the reimbursement process and can assess if your practice is a fit for increasing revenue/patient health.

To learn more, please drop us a line at sales@circlelinkhealth.com or call 917-999-6560.

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NOTE:  FQHCs/RHCs may not bill for the new CCM and RPM codes. However, patients meeting PCM requirements are billable under the G0511 FQHC/RHC care management code.