Primary Care Coding Alert

TCM, CCM, receive rigorous revisions and reevaluation.

In addition to the addition of principal care management (PCM) that we reported about in last month’s Primary Care Coding Alert, the 2020 Physician Fee Schedule (PFS) final rule contained revisions to chronic care management (CCM) and transitional care management (TCM) that will have a big effect on your care management reporting this year.

Here are the five big changes you need to know.

1) TCM Gets Unbundled …

If you report TCM using 99495 (Transitional Care Management services … within 14 calendar days of discharge) or 99496 (Transitional Care Management services … within 7 calendar days of discharge), you’ll be pleased to know that the Centers for Medicare & Medicaid Services (CMS) has unbundled the services to allow concurrent billing with the following codes:

• 90960-90962, 90966, 90970 (ESRD related services …) for end stage renal disease (ESRD) services for patients over the age of 20;
• 93792 (Patient/caregiver training …) and 93793 (Anticoagulant management …) for international normalized ratio (INR) monitoring services;
• 99091 (Collection and interpretation of physiologic data …) for data analysis;
• 99358-+99359 (Prolonged E/M services …) for non-face-to-face prolonged services;
• 99490-99491 (Chronic care management services …) for CCM;
• 99487-+99489 (Complex chronic care management …) for complex CCM; and
• G0181 and G0182 (Physician supervision of a patient receiving Medicare services …) for care plan oversight services.

Coding alert: “Even though CMS has unbundled all these services with TCM, the CCM and complex CCM codes remain unaffected by the decision and are still bundled with the other services,” says Donelle Holle, RN, president of Peds Coding Inc., and a healthcare, coding, and reimbursement consultant in Fort Wayne, Indiana. Additionally, you still won’t be able to count the same time toward two different services. So, time counted for TCM, for example, still cannot be counted toward CCM if the two services are performed on the same date.

2) … and Revalued

Better still, your bottom line will go up this year if you bill for TCM. That’s because the 2020 final rule increased the work relative value units (RVUs) for 99495 from 2.11 to 2.36 and for CPT^® code 99496 from 3.05 to 3.10.

Naturally, “the increase in value and expansion of the list of services that can be reported concurrently with TCM are both good things from a primary care perspective,” says Kent Moore, senior strategist for physician payment at the American Academy of Family Physicians. “Not only will PCPs get paid more for the TCM services they provide, but they will also have the opportunity to separately report, and get paid for, other services previously bundled with TCM. This may make it more attractive and/or feasible for PCPs to provide TCM in 2020 and beyond,” Moore adds.

3) CCM Gets an Add-on Code …

The final rule also announced that 99490 (Chronic care management services, at least 20 minutes of clinical staff time …) will receive a new add-on code, HCPCS code G2058 (Chronic care management services, each additional 20 minutes of clinical staff time directed by a physician or other qualified health care professional, per calendar month (List separately in addition to code for primary procedure)), which “will be reportable a maximum of two times within a given service period for a given beneficiary.”

Experienced coders have also greeted the decision with approval. “G codes are typically used by Medicare, so this is an exciting revision as long as all the insurance carriers will accept the G code,” Holle notes.

Additionally, “the add-on code means that 99490 will no longer be open-ended, and Medicare beneficiaries requiring more time for CCM will potentially generate more revenue to cover the extra costs,” notes Moore. “It’s also consistent with the direction CPT^® is going to go in 2021,” Moore also points out.

4) … with a Care Plan Change

CMS has also revised the CCM typical care plan, eliminating the phrase “community/social services ordered, how the services of agencies and specialists unconnected to the practice will be directed/coordinated, identify the individuals responsible for each intervention” from the typical care plan language and replacing it with the phrase “interaction and coordination with outside resources and practitioners and providers.” This should simplify the way your provider implements this aspect of CCM for any given patient.

The final rule also removes the requirement for substantial revision of the patient’s care plan when reporting 99487 and +99489. That’s because “CMS believes patients needing complex CCM implicitly need and receive substantial care plan revision, which makes the service component of substantial care plan revision potentially duplicative with the medical decision-making service component and, therefore, unnecessary as a means of distinguishing eligible patients,” Moore explains.

5) And CMS Makes RPM a Care Management Service

Lastly, CMS has continued its designation of 99457 (Remote physiologic monitoring treatment management services…; first 20 minutes) and +99458 (… each additional 20 minutes) as care management services under CMS regulation Section 410.26(b)(5), which means “the services can be furnished under general supervision … of the ‘physician or other qualified health care professional …’ when these services or supplies are provided incident to the services of a physician or other qualified healthcare professional.” The code was actually designated this way in 2019, but CMS continued the designation in 2020 under the code’s new time parameters.

Don’t forget: CPT^® changed the time parameters for 99457, and created +99458 as an add-on code, effective Jan 1, 2020. So, if you bill for RPM, make sure that you document the first 20 minutes of the service with the base code, adding each additional 20 minutes with +99458 when appropriate.

To view the full PFS final rule for 2020, go to s3.amazonaws.com/public-inspection.federalregister.gov/2019-24086.pdf.