Gastroenterology Coding Alert

Question: One of our patients had been recently discharged from the hospital due to a severe Crohn’s disease flare-up which led to severe complications. Our provider determined he should monitor and manage the patient from the patient’s home. Can we bill chronic care management (CCM) and care plan oversight (CPO) together?

Virginia Subscriber

Answer: Unfortunately, the answer is no. It’s a common misconception, but physicians can’t report CCM codes such as 99490 (Chronic care management services … first 20 minutes of clinical staff time directed by a physician or other qualified health care professional, per calendar month.) and 99491 (Chronic care management services… first 30 minutes provided personally… per calendar months) with home health care plan oversight code G0181 (Physician or allowed practitioner supervision of a patient receiving Medicare-covered services provided by a participating home health agency (patient not present) requiring complex and multidisciplinary care modalities involving regular physician or allowed practitioner development and/or revision of care plans) or CPO code G0182 (Physician supervision of a patient under a Medicare-approved hospice (patient not present)… 30 minutes or more). Medicare does not allow these codes to be billed together “because the comprehensive care management included in CCM could significantly overlap with these [CPO] services,” according to the Centers for Medicare & Medicaid Services (CMS). (https://www.cms.gov/files/document/ chronic-care-management-faqs.pdf)

However, if your provider doesn’t meet the 30-minute criteria or doesn’t have adequate documentation to support the CPO codes, billing for the less time-intensive CCM might be a viable option.

Note: CCM codes don’t conflict with services related to certifying or recertifying a home health patient’s plan of care. This is because codes G0180 (Physician or allowed practitioner certification for Medicare-covered home health services under a home health plan of care (patient not present) and G0179 (Physician or allowed practitioner re-certification for Medicare-covered home health services under a home health plan of care (patient not present)…) don’t require time documentation.