To be properly reimbursed by Medicare for select chronic care management (CCM) services not previously eligible for payment, documenting all conditions and satisfying requirements is critical, including the most challenging requirement, the ’20 minutes a month’ rule, says Rick Hindman, attorney with McDonald Hopkins, a law firm that advises a nationwide client base extensively on healthcare reimbursement.
It’s crucial to have systems in place and to document that all of the chronic care management conditions and all of the requirements are being satisfied. Some elements that could be particularly challenging include the ’20 minutes per month’ rule. The practice needs to have a way to show and document that for each beneficiary for whom the services bill in the given month, chronic care management, that there’s actually 20 minutes of services. There needs to be a system in place to record the time and reflect that within the practice’s records.
Also, the documentation needs to show that all requirements are being satisfied, including the electronic health record (EHR). The documentation has to show that the scope of services, including continuity of care and care management, transition management, coordination of care, and enhanced access, is satisfied. The supervision has to be documented. The general supervision standard needs to be documented. Also, beneficiary consent needs to be documented and must be part of the EHR, and availability on a 24/7 basis must be documented somewhere in writing.
Physician Reimbursement for Chronic Care Management: Identifying New Practice Revenue Opportunities offers practical guidance to prepare physician practices to maximize CCM reimbursement in the new year.This 25-page resource draws from the 2015 Medicare Physician Fee Schedule to identify new sources of payment for physician practices while improving care coordination for beneficiaries with chronic illness.