Home Health & Hospice Week

Industry Note:

OIG Focus On Physician Topic Could Affect Home Care

Watchdog agency singles out Chronic Care Management billing for scrutiny.

Do your referring physicians know how their CCM billing interacts with billing for home care-related services? If not, it could get them into hot water with the HHS Office of Inspector General and other reviewers.

The OIG outlines two areas of concern for Part B providers in its 2017 Work Plan: chronic care and transitional care management. With strict guidelines to follow, the OIG suggests your referral sources remember that these services are not covered under these CPT® codes:

  • CCM falls under the CPT® code 99490 (Chronic care management...) and refers to nonface-to-face care for Medicare beneficiaries that have multiple chronic issues. The OIG reminds that “CCM cannot be billed during the same service period as transitional care management, home health care supervision/hospice care, or certain end-stage renal disease services.”
  • The CPT® code range 99495-99496 (Transitional Care Management Services…) targets TCM services, but the OIG warns that “Medicarecovered services, including chronic care management, end-stage renal disease, and prolonged services without direct patient contact, cannot be billed during the same service period as TCM” and are therefore not covered under them.

Plus: Violation of the Stark Law is also high on the OIG’s radar. Advise your referral sources to have ready clear documentation that their financial relationships are in check and that the services, drugs, or products were both medically necessary and reasonable.

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