Medicare Compliance & Reimbursement

Chronic pain management (CPM) has been a hot topic for Medicare Part B providers for years — and now you’ve got two new codes for these services.

Read on to discover what the CPM codes include and to learn the not-so-obvious coverage requirements revealed in the calendar year (CY) 2023 Medicare Physician Fee Schedule (MPFS) final rule.

Take Your Time Reading the Descriptors

The descriptors for the new CPM codes are long, and you must read them carefully to understand the requirements. The italicized wording below quotes the code descriptors, but adds bullets in G3002 to make it easier to identify each element:

• G3002 ((Chronic pain management and treatment, monthly bundle including,
• diagnosis;
• assessment and monitoring;
• administration of a validated pain rating scale or tool;
• the development, implementation, revision, and/ or maintenance of a person-centered care plan that includes strengths, goals, clinical needs, and desired outcomes;
• overall treatment management;
• facilitation and coordination of any necessary behavioral health treatment;
• medication management;
• pain and health literacy counseling;
• any necessary chronic pain related crisis care; and
• ongoing communication and care coordination between relevant practitioners furnishing care, e.g. physical therapy and occupational therapy, complementary and integrative approaches, and community-based care, as appropriate.
• Required initial face-to-face visit at least 30 minutes provided by a physician or other qualified health professional;
• first 30 minutes personally provided by physician or other qualified health care professional, per calendar month. (When using G3002, 30 minutes must be met or exceeded.)))
• +G3003 (…Each additional 15 minutes of chronic pain management and treatment by a physician or other qualified health care professional, per calendar month. (List separately in addition to code for G3002. When using G3003, 15 minutes must be met or exceeded.))

Dig Deeper to Grasp the Finer Points

As detailed as the code descriptors are, there is a lot more you need to know to apply these codes accurately. The MPFS final rule answers many questions in its discussion of these codes. To read the specifics, go to www.federalregister.gov/d/2022- 23873/page-69524 and scroll to the header “(33) Chronic Pain Management and Treatment (CPM) Bundles ….”

Descriptor elements required? Providers must furnish all appropriate elements of the code descriptor. The key term is appropriate because not all patients require every element.

Chronic pain definition: For these codes, Medicare defines chronic pain as “persistent or recurrent pain lasting longer than 3 months.”

At the first visit, the patient doesn’t need to have an established history or diagnosis of chronic pain. The patient also doesn’t need to be diagnosed with a condition that causes or involves chronic pain. But “it is the clinician’s responsibility to establish, confirm, or reject a chronic pain and/or pain-related diagnosis when the beneficiary first presents for care and the clinician first reports” G3002, the final rule states.

In person: The first time you report G3002, a physician or other qualified healthcare professional (QHP) must see the patient in person in a clinical setting. Beyond that, the provider may decide to furnish any in-person components using telehealth to increase patients’ access to care.

Frequency: In conjunction with G3002 for the first 30 minutes, you may report +G3003 for each additional 15 minutes an unlimited number of times per calendar month.

Additional services: You may report both evaluation and management (E/M) and CPM codes on the same day when documentation shows the encounter met all requirements to report each service separately. Of course, you should not double-count time. In other words, don’t include time spent on another reported service when calculating the CPM time.

Similarly, Medicare allows you to report CPM and remote patient monitoring, remote physiologic monitoring, or remote therapeutic monitoring together when documentation supports doing so.

Multiple providers? The final rule “noted that it is unlikely that a patient with pain would want or need to see more than two physicians or other qualified health professionals in the same month to manage their pain through CPM, but declined to restrict the number of clinicians who can bill the CPM codes at this time,” say attorneys Carrie Nixon, Kaitlyn O’Connor, and Stephanie Barnes with law firm Nixon Gwilt Law in a blog post about the new codes.

The CY 2023 MPFS final rule provides some examples on coding. Scenario 4 explains that it may be appropriate for both a family physician and a pain management specialist to report G3002 in a single month if the family physician transfers care to the pain management specialist.

Expect Slightly Higher Pay in Office Setting

While the final rule gave only the work relative value units (RVUs) for the new codes, the MPFS file for the first quarter of 2023 shows G3002 has 2.39 total RVUs in the nonfacility setting and 2.17 RVUs in the facility setting. If you multiply that by the 2023 conversion factor of $33.8872— which was updated in the omnibus budget bill on Dec. 29, 2022 (see Medicare Compliance & Reimbursement, Vol. 29, No. 1) — results are roughly $80.99 (nonfacility) and $73.54 (facility). For +G3003, the nonfacility total RVUs of 0.87 and facility RVUs of 0.75 calculate to about $29.48 and $25.42.

Resource: Review the CY 2023 MPFS at www.govinfo.gov/ content/pkg/FR-2022-11-18/pdf/2022-23873.pdf.