CMS introduces CCM to address burden of chronic disease
In 2015, CMS rolled out the Chronic Care Management (CCM) codes to offer providers fee-for-service reimbursement for providing non-traditional outpatient care management services to Medicare beneficiaries with two or more chronic conditions.
But uptake has been slow, in part because organizations don't know how to implement CCM codes. To help, we've outlined the strengths and weaknesses of the three major CCM implementation models organizations employ, including:
- Decentralized deployment model promotes integration and patient involvement
Organizations looking to use CCM as a lever to phase team-based care into their system should consider taking a decentralized approach to CCM deployment. Under a decentralized model, care management is embedded directly into practice infrastructure, and CCM staff (e.g. RNs, LPNs, MAs) are collocated with billing providers (e.g. physicians, NPs, PAs). The close proximity of the care team fosters collaboration among team members. At the same time, the model gives patients the option to meet with their providers either virtually or face-to-face, allowing them to choose the care model that keeps them most engaged.
Unfortunately, every model has its drawbacks. By decentralizing CCM, organizations prioritize patient engagement over efficiency. Designating CCM staff to specific practices limits the potential number of patients they can enroll and manage. If there are not enough patients to engage in their assigned practices, staff are left with extra capacity. Additionally, office-based providers or team members may try to task CCM staff with extraneous office responsibilities.
To prevent these inefficiencies, some organizations centralize management of embedded care managers so that they're accountable to system-level—rather than office-level—oversight. This reporting structure has two added benefits: For one, it institutes a level of standardization across practices that's likely to be lost in an entirely decentralized model. Secondly, it facilitates scale, because decentralized care managers are able to provide virtual support to patients outside of their base clinic.
- Centralized deployment model allows providers to scale teams across a network
Under a centralized deployment model, providers house CCM staff at an offsite location and provide their patients with virtual care management. According to CMS, CCM staff are allowed to use "incident-to" billing under general—rather than direct—supervision. That means staff do not need to be in the same physical place as their billing providers to bill for CCM.
Advocates laud the efficiency of centralization, both in terms of the ability to reach the maximum number of patients and to ensure CCM staff time is used appropriately.
However, centralizing care management staff offsite may pose challenges to care team integration and patient engagement. Just as care team collocation helps facilitate natural coordination among team members, separation can make it more difficult. When it comes to patient engagement, patients may be less likely to enroll in CCM if it means working with someone they haven't met in person. This is true both for patients who have received face-to-face care management in the past through non-CCM programs, as well as those who are new to the offering altogether.
- Outsourcing CCM can provide short-term benefits without major investment
Finally, organizations that are not ready or able to build out an infrastructure that can support CCM may choose to contract out to a third party CCM vendor. Practices or organizations that outsource CCM add care management capacity without making structural investments in staffing and practice workflow changes. Additionally, CCM vendors can often yield higher-than-average enrollment and month-over-month billing numbers than provider organizations that develop the infrastructure in-house, which increases net revenue generated.
However, much of that revenue goes to the vendor, rather than the practices. CCM vendors are known to keep 60% to 70% of revenue generated. Perhaps more importantly, outsourcing CCM can void some programs' strategic goal of fostering a culture of team- and value-based care among its staff. So, while delaying investments in building out a value-based care delivery infrastructure may not negatively affect providers immediately, it does affect their readiness to successfully take on new managed populations at scale.
To learn more about each of these models for implementing CCM codes and about the additional considerations crucial to successfully billing for CCM, join us at 1:00 p.m. on Thursday, July 26, for our webconference, How to implement Medicare's chronic care management codes.