Pharmacists working directly with providers may have the opportunity to reach even more patients with the CMS Revisions for 2020.
Many people have been awaiting the results from CMS to see if the proposed changes for 2020 would be approved. Who knew that 996 pages of content could change the way we practice collaborative care. Pharmacists working directly with providers may have the opportunity to reach even more patients with additional services, changes to provider supervision requirements, and revisions to the rules for currently existing programs. Explore the new codes for CCM and RPM, and much more!
What are the changes for Chronic Care Management (CCM)?
Due to the feedback from many people conducting CCM services, CMS proposed a new code for 2020 that would allow providers to bill for additional time beyond the 20 minutes for non-complex CCM. They finalized a new code, G2058, that can be billed for additional increments of 20 minutes for qualifying CCM time. This code will be reportable for a maximum of twice during a calendar month period for a given beneficiary. Since CCM time often goes above and beyond the 20 minute billing threshold but not quite to the 60 minute threshold for complex CCM, this new code presents an opportunity to improve the profit design of CCM programs. If 60 minutes of time is recorded per calendar month, it will be up to the provider to determine if it is appropriate to use the non-complex CCM code with the G2058 code or the code for complex care management, depending on the level of medical decision making.
CCM Codes for 2020
Additionally, CMS acknowledged the ambiguity surrounding the language for the CCM care plan. They reported that they found some of the original language for this to be redundant and burdensome for providers offering CCM services to their patients. Some language was eliminated while other language was revised to provide a simpler description of the requirements for the CCM care plan. One thing to look out for when these changes go into effect would be the modification of various templates and platforms to reflect the newer language for care plan requirements.
Revised Language for CCM Care Plan
What are the changes for transitional care management (TCM)?
Even with the growing number of TCM claims being submitted, it was found that the utilization of TCM services is low when compared to the number of eligible discharges for Medicare beneficiaries. For this reason, CMS proposed to remove the restrictions for concurrent billing with 14 care management codes. One of these such care management services is chronic care management. This presents a huge opportunity for pharmacists to participate in TCM activities needed to keep patients from returning to the hospital while also not ruling out the opportunity to bill for CCM activities during the same 30-day period. CMS is also proposing to increase the fee schedule for TCM services due to the administrative burden and lower utilization of the code. The intent is to pay a reasonable amount to compensate for the additional requirements of this code when compared to the traditional office visit.
What are the changes for Chronic Care Remote Physiologic Monitoring (RPM)?
One of the biggest awaited changes for RPM was the transition from direct supervision to general supervision and these proposed changes were finalized for 2020! This presents a tremendous opportunity for pharmacists to maximize non face-to-face services from a remote location. Similarly to CCM, an additional code was added to RPM to cover an additional 20 minutes of clinical staff time during a calendar month. Code 99458 was established to account for the additional time that many practices were spending on patients enrolled in RPM programs. One of the challenges of this newer program is that there is a lot of uncertainty surrounding the billing rules for the RPM program. CMS did provide clarity on the use of RPM services within the FQHC and RHC setting. CMS reported that since RHCs are paid an all-inclusive rate and FQHCs are paid the PPS rate, all services and supplies are included in this rate. Therefore, RPM will not be a separately billable service within these settings.
Remote Physiologic Monitoring Codes
What does this mean for pharmacy?
These changes provide a snapshot of the CY 2020 Revisions but do not describe the full impact of the changes to the value-based care model. There are many opportunities for pharmacists to make an impact through non face-to-face services as well as services such as transitional care management. As the medication experts, pharmacists can expand the knowledge of the care team and serve as a valuable resource for patients enrolled in these services. Pharmacists who take advantage of these changes can design meaningful programs that take the profession beyond the bench and show the value of their cognitive services with the goal of making this collaboration between pharmacists and providers a standard in the value-based care model.
Wanting to learn more? Consider our Collaborative Clinical Track: Discovery Edition (CCTDE) bundle of pre-recorded content, eligible for 8+ hours of CPE credit. If you're looking for something more advanced, consider our upcoming Virtual ALIE.
References:
1. Centers for Medicare & Medicaid Services. Medicare Program; CY 2020 Revisions to Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment Policies; Medicare Shared Savings Program Requirements; Medicaid Promoting Interoperability Program Requirements for Eligible Professionals; Establishment of an Ambulance Data Collection System; Updates to the Quality Payment Program; Medicare Enrollment of Opioid Treatment Programs and Enhancements to Provider Enrollment Regulations Concerning Improper Prescribing and Patient Harm; and Amendments to Physician Self-Referral Law Advisory Opinion Regulations Final Rule; and Coding and Payment for Evaluation and Management, Observation and Provision of Self-Administered Esketamine Interim Final Rule. Woodlawn, MD: Federal Register, 2019.
2. Centers for Medicare & Medicaid Services. Chronic Care Management Services. Available at: https://www.cms.gov/Outreach-and-Education/Medicare-Learning-Network-MLN/MLNProducts/Downloads/ChronicCareManagement.pdf. Accessed November 15, 2019.
3. Pillsy.com. What You Need to Know About 2019 Medicare CPT Codes For Remote Patient Monitoring (RPM) — 99453, 99454 and 99457. Available at: https://www.pillsy.com/articles/remote-patient-monitoring-rpm-2019-cpt-codes-medicare-99453-99454-99457. Accessed November 15, 2019.
Originally published on Medium by the Avant Institute on November 19, 2019.
