Gastroenterology Coding Alert

Reader Questions:

Check Out This CCM Caveat

Question: I know that typically the physician establishes a care plan in chronic care management (CCM), but are there any circumstances where that can be done by clinical staff?

California Subscriber

Answer: Yes, there are circumstances where the establishment of a plan can be performed by clinical staff. For example, a physician might identify a patient who is a good candidate for CCM during an office visit. The patient agrees to receive CCM services, but the physician doesn’t have time right then to develop the care plan (e.g., because the physician’s schedule is booked solid for a long time, he/she is leaving for vacation later that day, etc.). So, the physician might delegate establishment of the plan to an appropriate clinical staff person (e.g., nurse care manager). Later, that physician will need to review the plan and either confirm it meets expectations or makes necessary adjustments.

So, while the clinical staff member can establish the plan, the physician has to approve it or adjust it to meet the patient’s needs. There must be collaboration with the physician or other qualified health care professionals to ensure that the plan aligns with the standard of care. Remember that the physician is ultimately responsible for the patient’s care, and therefore they need to sign off on any CCM plan before it’s put into action.