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The case for outsourcing chronic care management

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growing population of <strong>chronic</strong>ally ill Medi<strong>care</strong> patients. Such patients<br />

can be the most expensive participants in the health<strong>care</strong> system, since<br />

they tend to rely more heavily on ERs and become hospitalized more<br />

often. <strong>The</strong> CDC has estimated that about 85% of Federal health<strong>care</strong><br />

dollars are allocated to the treatment of <strong>chronic</strong> conditions. For just<br />

the top seven most prevalent <strong>chronic</strong> diseases, the estimated cost of<br />

treatment in 2013 was $1.3 trillion.<br />

Care <strong>management</strong> <strong>for</strong> these <strong>chronic</strong>ally ill patients has been proven to<br />

improve outcomes and reduce costs. Care plan development, medication<br />

reconciliation, coordination of <strong>care</strong> with other providers (such as specialists),<br />

arrangement <strong>for</strong> social services, remote patient monitoring and<br />

other services all have have benefits to patients and help to contain<br />

costs. And yet, physicians were allowed by CMS to bill only <strong>for</strong> the time<br />

they spent with patients during office visits.<br />

That changed in January 2015 when CMS introduced CPT code 99490<br />

to encourage wider CCM availability to patients. Health<strong>care</strong> providers<br />

may now bill <strong>for</strong> non-office <strong>care</strong> given to Medi<strong>care</strong> patients with two or<br />

more <strong>chronic</strong> conditions. (<strong>The</strong> list currently includes nearly 30 conditions,<br />

and is evolving. Visit www.cms.gov or ask your Wellbox representative<br />

<strong>for</strong> the most current list.) <strong>The</strong> CMS has responded not only to<br />

cost concerns, but also to patients’ expressed preference to receive as<br />

much <strong>care</strong> as possible in their homes rather than in hospitals or offices.<br />

Requirements, billing and reimbursement<br />

To bill <strong>for</strong> CCM, practices must meet specific requirements, the<br />

most important being the development of a <strong>care</strong> <strong>management</strong> plan,<br />

followed by provision of at least 20 minutes of non-visit-based <strong>chronic</strong><br />

<strong>care</strong> ser vices per month. <strong>The</strong> average reimbursement <strong>for</strong> 99490 is $43<br />

per patient per month. If in a given month, a patient is both seen at the<br />

office and receives non-face-to-face <strong>care</strong> <strong>management</strong>, both incidents<br />

are billable that month.<br />

However, as noted in a recent article in <strong>The</strong> Annals of Internal<br />

Medicine 1 , “CCM reimbursement presents both an oppor tunity and<br />

a dilemma <strong>for</strong> practices....Delivery of CCM services may take time<br />

away from routine patient visits and require hiring ad ditional staff.<br />

Thus, although the CCM payment could result in nearly $500 in annual<br />

revenue per eligible Medi<strong>care</strong> patient, practices may hesitate to seek<br />

these payments because much of this revenue may be offset by costs<br />

incurred to meet CMS requirements.”<br />

Who can provide<br />

CCM services?<br />

While CPT code 99490 can only be<br />

billed by one provider per patient, the<br />

profile of those <strong>care</strong> providers is broadly<br />

defined by CMS and includes:<br />

• Physicians (regardless of specialty)<br />

• Advanced practice registered<br />

nurses<br />

• Physician assistants<br />

• Clinical nurse specialists<br />

• Certified nurse midwives<br />

• Certified medical assistants<br />

Eligible practitioners must act within<br />

their State licensure, scope of practice<br />

and Medi<strong>care</strong> statutory benefit. Services<br />

provided directly by an appropriate<br />

physician or non-physician practitioner,<br />

or other clinical staff “incident to” the<br />

billing physician practitioner, counts<br />

toward the minimum service time<br />

required to bill <strong>for</strong> CCM services per<br />

calendar month.<br />

Non-clinical staff time cannot be<br />

counted towards the minimum CCM<br />

monthly services; however, CCM<br />

services may be recorded by nonclinical<br />

staff.<br />

Which providers are not eligible to<br />

bill Medi<strong>care</strong> <strong>for</strong> CCM? Other nonphysician<br />

practitioners and limitedlicense<br />

practitioners (e.g., clinical<br />

psychologists, social workers) are<br />

precluded from billing 99490. Also,<br />

non-clinical staff time may not be<br />

counted toward billable hours of CCM.<br />

In the AIM article, data was presented that compared the revenue

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