Medicare Compliance & Reimbursement

Good news: General supervision a go for CCM services.

When the Centers for Medicare & Medicaid Services (CMS) released the proposed Medicare Physician Fee Schedule for 2015, supervision requirements for chronic care management services were set to be tighter. CMS cut some slack in the final rule, so make sure you’re up to date with the latest policies regarding who can perform CCM services.

Advanced Practitioners, such as nurse practitioners and physician assistants, can provide and bill for CCM services independently — but only at 85 percent of the reimbursable rate. APs can, however, receive 100 percent of the reimbursable rate, if they are supervised — and providers get the good end of the deal this time around.

Key: “Currently, any practitioner who wishes to bill in a physician’s name requires ‘direct supervision’ — e.g., the physician must be available in person, on site, to assist the staff,” says Krista Teske, senior analyst of research and insights at The Advisory Board Company. “However, CMS has made it clear that for this new chronic care management code they will instead only require ‘general supervision’ — e.g., the physician only has to be available by phone.”

The flexibility doesn’t stop there. “Unlike what was previously proposed, the clinical staff performing the CCM services do not need to be direct employees of the provider or practice,” Teske says. 

“In addition, the practitioner who provides the ‘general supervision’ does not need to be the same person under whose name the chronic care management code is billed. In other words, groups can choose to outsource both the care management services and the supervision of these services to contractors,” she adds.

Finally, take note that any physician who performs CCM services can bill for the code, not just primary care providers.