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On Nov. 1, 2019, the Centers for Medicare & Medicaid Services (CMS) issued the 2020 Medicare Physician Fee Schedule (MPFS) Final Rule, which continues the trend of encouraging   care management activities by making it easier and more financially attractive to furnish chronic care management (CCM), transitional care management (TCM) and remote physiologic monitoring (RPM) services for Medicare patients.

Care Management

CMS has been expanding Medicare reimbursement for care management and coordination since 2013, when Medicare began paying under TCM codes for managing patient transitions from acute care and certain outpatient settings for the first 30 days after discharge. Since 2015, Medicare has been paying physicians, non-physician practitioners (NPPs), their practice entities, federally qualified health centers (FQHCs) and rural health clinics (RHCs) under CCM codes for managing and coordinating care for patients with two or more chronic conditions, and in 2017 loosened administrative requirements for CCM and added codes for complex CCM. Also in 2017 Medicare began paying under behavioral health integration codes for managing behavioral health conditions.  Medicare began paying for RPM in 2018 and extended payment to additional RPM codes in 2019.  

In its MPFS commentary CMS observed that use of care management codes has been increasing, but that TCM and CCM continue to be underutilized. CMS cited administrative burdens and low reimbursement as impediments to increased use of TCM and CCM.

Transitional Care Management (TCM)

CMS has identified 16 billing codes that currently cannot be billed concurrently with TCM. In an effort to increase utilization of TCM, CMS will remove this bar on current billing, and will increase payment rates for TCM.

Chronic Care Management (CCM) and Principal Care Management

CMS is implementing the following CCM changes starting January 1, 2020:

  • CMS is establishing an add-on code (G2058) for each 20 minute increment of additional CCM time (on top of the 20 minutes required under CPT 99490, the basic code for non-complex CCM).
  • CMS will loosen the comprehensive care plan element under the complex CCM codes (99487 and 99489), which currently requires establishment or substantial revision of a comprehensive care plan, to also allow this element to be satisfied by implementing or monitoring a comprehensive care plan.
  • CMS is revising the list of typical care plan elements to provide a more general description of interaction and coordination with outside resources and providers (in place of the current reference to community/social services and identifying individuals responsible for interventions). CMS noted that there was some confusion about what a care plan typically includes and that the current language (prior to this revision) may be redundant or unduly burdensome.
  • Medicare will begin paying under a new principal care management code for patients with a single chronic condition (in contrast with the current CCM codes that apply only to patients with multiple chronic conditions). 

Remote Physiologic Monitoring (RPM)

The 2020 MPFS final rule will encourage RPM in several ways:

  • An additional RPM code (99458) will provide additional payment for 20 more minutes (on top of the current 20 minutes under 99457) of RPM services in a given month. 
  • CMS is adding RPM to the definition of “designated care management services” for purposes of “incident to “ supervision, so that RPM services can be furnished under general supervision and therefore the clinical staff member and the supervising physician or NPP will not be required to be in the same location. This change will make it more feasible for clinical staffing companies to participate in providing RPM services under contract with the provider.

Some commenters requested definitions of RPM code descriptor terms that they viewed as unclear, such as “physiologic parameters”, “digitally transmitted data”, “medical device”, and “interactive communication.” CMS stated that it will consider these definitions and other RPM questions in future rulemaking.  

In addition, CMS clarified its position that RPM is already included in the all-inclusive rates paid to RHCs and FQHCs, and that therefore RPM is not separately billable by RHCs and FQHCs.

Communication Technology-Based Services (CTBS)

CMS is finalizing a policy permitting a single patient consent for multiple CTBS or interprofessional consultation services, such as remote evaluation of recorded video (G2010), virtual check-in (G2012), interprofessional telephone/Internet/EHR assessment and management consultations (99446-99449, 99451 and 99452). The single consent will need to be renewed at least annually.

The MPFS Final Rule is scheduled to be published in the Federal Register on November 15, 2019.

For more information, please contact the attorney listed below.

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