The Center for Medicare & Medicate Services (CMS) has recently published updates to their frequently asked questions about billing medicare for chronic care management services. The most recent version comes as of March 17, 2016. The nine page PFD outlines common questions around the physician fee schedule and chronic care management (CCM) and hospital outpatient payment systems. To keep you up to date with chronic care management requirements & compliance we have included a few highlights below. The entire PDF can be viewed on the cms.gov website here.
Can CCM be subcontracted to a third party?
Yes, the billing physician or other qualified health care professional can arrange to have CCM services provided by a clinical staff member that is external of the practice. They must insure that all "incident to" and other rules are met to bill for CCM.
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Is a new patient consent form required each month or annually?
No, as of the final rule CY 2014 PFS consent is only required if the patient changes the billing practitioner. This means consent must only be obtained once prior to billing the service. If the patient changes a new consent form must be signed before any services are rendered.
Does Medicare now pay separately for remote patient monitoring services?
Similar codes like CPT 99091 continue to be bundled with other services yet they can not be billed at the same time as CPT 99490. This includes codes 99090 and 99091.
This does not mean that remote monitoring technologies can not count towards 99490. For example, Oculus Health connects with over 200 connected fitness and health trackers. Remote monitoring using tools like the Jawbone Fitbit, Apple Health app, or a connected glucose monitor all count towards the 20 min required per month for CPT 99490. However this can not be the only work that is done to meet the requirements. This time can only be counted once and not for more than one billing code.
Data is key to the future of healthcare and a large part of Chronic Care management. Dr. Drew Harris director of health policy at Thomas Jefferson School of Population Health wrote in the WSJ, "Can your doctor whose income depends on keeping you healthy use data describing your physical activity, sleep patterns and other bodily functions to improve diagnosis and treatment? When a wearable device detects significant changes in a senior’s movement or mental status, will the proper flag go up at their doctor’s office?". We are excited to be leading the charge in incorporating remote devices to care plans.
Are Hospital outpatient department able to bill for CPT code 99490 under the OPPS?
CPT code 99490 is payable under OPPS but certain requirements must be met. For hospitals to bill for code 99490 they must ensure that the OPPS provides payment to the HOPD when the hospital's clinical staff furnishes the services. The services must still be under the direction of the physician.
What supervision level must be met for CCM services administered in a hospital setting?
To meet the requirements to bill for 99490 general supervision level under the OPPS must be met in a hospital setting. This means that the physician does not need to be present at the time of the procedure though under general supervision they must oversee the direction and overall control.
Can a hospital bill for more than one unit if they provide more than 20 minutes of CCM?
Like a smaller practice a hospital can not bill more than once a month for CCM. They also must ensure they are the only provider billing for the patient for CCM services. Though there is a minimum of 20 minutes a month of CCM services CMS has not specified a maximum. No matter how many minutes over the minimum hospitals and doctors offices can only bill one unit and one line item for CPT code 99490.