Medicare Chronic Care Management Code: Stepping Stone to Medical Home, ACO

Monday, February 23rd, 2015
This post was written by Patricia Donovan

New CCM codes offer physician practices both a business opportunity and a path to providing value-based healthcare.

For physician practices yet to embrace a patient-centered medical home or accountable care organization (ACO), the new Medicare Chronic Care Management (CCM) code offers another benefit besides added revenue: the chance to test-drive a value-based healthcare delivery model.

Billing via the new CPT code 99490 is “an opportunity for practices to develop the infrastructure to become a medical home or to participate in an ACO,” noted Nicole Liffrig Molife, counsel with Arnold & Porter during a February 2015 webinar, Chronic Care Management Reimbursement Compliance: Overcoming Obstacles and Meeting Requirements.

The law firm, which counts the American Geriatric Society among its clients, has closely monitored the development by CMS of the CCM code, which reimburses practices for select non face-to-face care coordination tasks previously bundled into Evaluation and Management (E&M) codes.

“[CMS] has been pretty explicit…that they conceive of this code as a transition toward an alternative payment model,” added Paul Rudolf, MD, a partner with Arnold & Porter. The transitions seems inevitable, given the federal payor’s aggressive timeline for transitioning Medicare payments to value-based models announced last month.

Transforming themselves via this added CCM payment would jump-start development of the technology, communications and staff required for practices to provide complex, coordinated care management for Medicare beneficiaries with multiple chronic conditions, said Dr. Rudolf, a former practicing physician&#151activities at the heart of patient-centered healthcare models.

The two attorneys walked through the requirements to bill CCM, including patient eligibility, professional eligibility, patient consent, care coordination services, specified practice capabilities, and specified use of an electronic health record (EHR).

They also identified several gray areas in the CCM requirements, offering guidance on handling the following:

  • The scope of diseases or conditions considered ‘chronic;’
  • Credentials for clinical staff performing CCM services;
  • Activities and requirements of ‘general supervision;’
  • Handling retroactive patient consent;
  • CCM activities that must be documented in the electronic health record;
  • Access by contracted staff of the patient’s care plan;
  • Location where the care plan must reside;

Until Medicare provides more clarity, practices should thoroughly document CCM activities and, where necessary, consult their in-house ethical professionals and specialty societies to protect themselves, Dr. Rudolf said.

Noting the proliferation of CCM guidance in the marketplace, some of which may appear inconsistent and conflicting in nature, he advised providers to vet thoroughly any CCM advice before implementation.

Click here for an interview with Dr. Rudolf.

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