This is the part two of the Chronic Care Management: Inquiring Minds Want to Know series. Click here for part one, including introductory information and top CCM questions 1-5.
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6. When filing a claim for CCM, what should be listed as the date of service? As the site of service? As the relevant diagnosis?
CMS has stated that there are no claims edits in place for date of service, site of service or diagnosis codes, and thus CCM claims will not be denied based on the information listed for these items. As a practical matter, we recommend the date of service be the date on which the 20-minute requirement is satisfied, the site of service be listed as the practitioner’s primary practice location, and that at least two of the beneficiary’s chronic conditions be listed as the diagnosis codes. Note: When listing the site of service, ensure that the location selected is associated with the practitioner in Medicare Provider Enrollment, Chain, and Ownership System (PECOS) to avoid unnecessary claims issues.
7. When should a claim for CCM be submitted?
Again, CMS has not provided guidance on this point, but we believe it is appropriate to submit the claim any time after the 20-minute requirement has been satisfied for that calendar month.
8. How should the subjective acuity test be applied?
To be eligible for CCM, a beneficiary must have two or more chronic conditions (the objective condition test) 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 (the subjective acuity test).
During the NPC, the CMS representative noted that two-thirds of Medicare beneficiaries have two or more chronic conditions, and explained that CCM was intended to reach as many of these beneficiaries as possible. It seems, therefore, the subjective acuity test was not intended to restrict access to CCM; instead, it was intended to identify those beneficiaries who would benefit from 20 minutes of care management services. So long as legitimate and beneficial non-face-to-face services are being furnished to the beneficiary, the subjective acuity test should not otherwise limit access to this care.
9. Who is qualified to provide non-face-to-face care management services?
To be counted, non-face-to-face care management services must be performed by licensed clinical staff under the general supervision of a physician. This includes any person with a state-issued license in a healthcare profession, as well as medical assistants credentialed by a third-party organization. Regardless of licensure or credentials, no person should provide any service beyond his or her training and competency.
10. What does it mean to electronically capture care plan information?
The electronic care plan – one of the key requirements for billing CCM – must be maintained in electronic format. The plan must be available on a 24/7 basis (by means other than facsimile) to members of the care team, and the provider must be capable of transmitting the plan (by means other than facsimile) to other providers involved in the patient’s care. Also, the provider must furnish an electronic or paper copy of the care plan to the beneficiary.
The plan does not have to be generated using a certified electronic health record, nor does it have to be maintained in an EHR. The information in the care plan may come from paper documents (such as a questionnaire completed by the beneficiary), but this information must be incorporated into the electronic document.
During the NPC, the CMS representative emphasized these were the care plan rules for 2015, implying that CMS is contemplating tightening these requirements in 2016. However, the representative gave no indication as to what CMS is intending to pursue.