While this is partially due to the administrative burdens CCM codes carried when they were first rolled out, many providers tell us that they're simply uncertain about how to implement the codes: Who can provide care? What services can they bill for?
Following our July webconference on implementing CCM codes, our CCM implementation experts answered your most pressing questions on billing for CCM activities. Here are the top two questions, along with their answers.
What roles do extended members of the care team play in CCM?
Only physicians, nurse practitioners, physician assistants, clinical nurse specialists, and certified nurse midwives can bill for this service, but clinical staff as defined by CPT* can furnish the service "incident to" any of these professionals.
- Licensed Practice Nurses can provide care planning for most patients receiving CCM, but should not be assigned to those requiring more complex care.
- Registered Nurses should mainly be used to assist with complex patients who require higher-level medical knowledge for care planning, to ensure everyone works at top of license.
- Medical Assistants (MAs) typically do not create or modify patient care plans, though licensure and scope-of-practice laws vary by state. Instead, MAs often help implement care management interventions, monitor patients, and provide logistical support such as scheduling patient transportation or coordinating care appointments.
*The Current Procedural Terminology (CPT) book defines a clinical staff member as "a person who works under the supervision of a physician or other qualified health care professional and who is allowed by law, regulation and facility policy to perform or assist in the performance of a specified professional service; but who does not individually report that professional service." So, team members (licensed social workers, clinical pharmacists, nutritionists, etc.) are able to track their time toward CCM if the services they administer meet Medicare’s “incident to” rules such as supervision, applicable State law, licensure and scope of practice.
Outside of face-to-face communication with the patient, what activities count toward billing for CCM?
First and foremost, to submit any CCM charges, providers must establish comprehensive care plans. The time they spend to do so is CCM-eligible. CMS expects providers to revise complex patient care plans (those billing 99487) on a monthly basis, and that time is also billable.
Any time that a member of the care team spends on logistical tasks such scheduling an appointment with a provider, following up with the patient to confirm, arranging logistical support (e.g. transportation to or from an appointment), or handling patient health information forms, is billable.
Any time that a provider spends communicating with a patient or their caregiver to coordinate care is billable, regardless of whether this communication happens via EHR portal or over phone, text, or email.
If you're interested in hearing our experts' take on other frequently asked questions, we'd be happy to send through a more comprehensive Q&A. Just email us at firstname.lastname@example.org.