CMS proposes payment for chronic care management in 2015

In the 2015 Proposed Physician Fee Schedule released on the eve of July 4 (CMS loves holiday releases of rules) CMS states they want to support primary care. One of the ways they are proposing to do this is to add a new benefit: chronic care management (CCM). They are proposing a rate of $41.92 for 20 minutes or more of this non-face-to-face service during a 30-day period.

Here’s how they define it Gxxx1: chronic care management services furnished to patients with multiple (two or more) chronic conditions expected to last at least 12 months, or until the death of the patient, that place the patient at significant risk of death, acute exacerbation/decompensation, or functional decline; 20 minutes or more; per 30 days.” (Gxxx1 is a dummy code. CMS will release the HCPCS code in November, when the release the Final Rule.) CMS will not use the CPT codes for complex chronic care coordination services 99487—99489. Those will continue to have a bundled status indicator.
In order to be eligible the patient must have two or more significant chronic problems, expected to last at least 12 months or be life long conditions. They must be the type of condition that poses a real risk to the patient’s health and well being. The practice must implement a care plan that addresses the patient’s conditions and spend 20 minutes during a 30-day period coordinating care and communicating with the patient. The practice must use a certified EHR. In 2015, the version must be certified to at least the 2014 Edition certified criteria. Everyone who has contact with the patient must have access to the electronic record. The EHR must have an electronic care plan accessible to all. The electronic record must include a full list of problems and medications and should facilitate caring for the patient during care transitions. Medication reconciliation is required as part of the service. The patient must have access to the practice 24 hours a day, 7 days a week. One provider must be designated for continuity of care. Care management includes assessment of the patient’s medical, functional and psychosocial needs.
The practice must create a patient-centered care plan, manage care transitions, and coordinate with home and community services. The care plan must be available electronically to all caregivers and available in an electronic or paper copy to the patient.
The practice must inform the patient that they will provide this service and get written consent from the patient to do so. The practice must also inform that patient that they can revoke this consent and stop receiving CCM services at any time. Document these communications in the record, and give the patient a written or electronic copy of the care plan. The co-pay and deductible are not waived for this service, but will be patient due.
CMS is proposing general, not direct, supervision of the clinical staff who perform these services. Nursing staff after hours or during normal business hours may perform these coordination services even if the physician or billing NPP is not in the office
It looks like a lot of work to me for $41.92. If the practice is already providing these services as part of a patient centered medical home, the service will be easier to provide and may not represent significant additional cost. The payment may support the additional infrastructure needed to manage the care of these patients.

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