Transitional Care Management (TCM) update

Date of service: use 29th day following discharge or counting day of discharge as day one, day 30.

Place of service: use place where mandated, bundled face-to-face E/M occurred.

What does licensed clinical staff mean?  No clarification yet from CMS.  FAQ being developed by them.  All staff must practice within their state scope of practice.

If patient is re-admitted during 30 day period, may still bill TCM 30 days after first discharge date if TCM services provided during the period.   May not report to TCM services, one for each discharge/TCM period.

14 thoughts on “Transitional Care Management (TCM) update

  1. We are piloting the TCM code in one of our clinics, and had a situation arise that prompted a question. A patient was discharged on a Sunday, and seen in the clinic on Tuesday. The 2 business day phone call was never completed as the patient was seen in the clinic before it occurred. All other required elements to bill TCM were completed.
    Have we met the requirements of the code, and could proceed with billing 30 days post discharge?

    • Since the CPT code allows for the second day contact to be “direct” and since there is no language that states the first contact and the E/M can’t be the same if they occur on day one or day two, I believe you have met the requirements for TCM.
      Thank you for posting the question here: it allows others to read the Q&A, and means I can share the information with many at once.

  2. We are currently participating through Health and Welfare as part of the Children’s Healthcare Improvement Collaboration. We receive a grant to have a Care Coordinator in our pediatric office. The Grant pays for her, but she is dedicated to work only under the supervision and direction of our physicians and coordinates care solely for our patients on-site of our pediatric office.
    1. Can this Care Coordinator perform the services represented by the TCM codes, i.e. 2 day phone call if we bill for these services?
    Per CPT, “…and/or licensed clinical staff under his or her direction.”
    2. Presuming she can, she has a Master’s in Public Health, will this meet the “Licensed Staff” criteria? It sounded like the CMS regulations were silent on the licensure element, but she is working under the Idaho scope of practice rules.

  3. Regarding TCM codes, are we required to input admit and DC dates on claim in order for Mcare to know the 30 day calculation is correct? If not, how do they know? I don’t see that info on FAQ website.

  4. TCM can be provided by any specialty. However, if the service is rendered by a NPP, can it be billed incident to the physician provided the incident to criteria has been met? Or, is this a service that if rendered by the NPP should be reported under their NPI?

  5. My supervisor just forwarded me an update from your newsletter stating that effective January 1, 2016 TCM charges can be reported on the date of face to face evaluation instead of on the 30th day from discharge. Would you please point me to a CMS / Medicare article or policy update that shows this change? I am unable to find anything on the Novitas Medicare website and we’d like to take this to our manager to change our TCM billing process.

    • I’m copying the header of the CMS 2016 Physician Fee Schedule rule, and the paragraph that describes it. You can download the rule for yourself, with the header information.
      DEPARTMENT OF HEALTH AND HUMAN SERVICES Centers for Medicare & Medicaid Services
      42 CFR Parts 405, 410, 411, 414, 425, and 495 [CMS-1631-FC]
      RIN 0938-AS40
      Medicare Program; Revisions to Payment Policies under the Physician Fee Schedule and Other Revisions to Part B for CY 2016
      Response: We will take these comments into consideration in the development of potential proposals for future PFS rulemaking. We will develop subregulatory guidance clarifying the intersection of fax transmission and CEHRT for purposes of CCM billing. Regarding TCM services, we are adopting the commenters’ suggestions that the required date of service reported on the claim be the date of the face-to-face visit, and to allow (but not require) submission of the claim when the face-to-face visit is completed, consistent with current policy governing the
      
      CMS-1631-FC 132
      reporting of global surgery and other bundles of services under the PFS. We will revise the existing subregulatory guidance for TCM services accordingly

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