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TJMiller

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With the new guidelines for TCM and CCM (from direct supervision to general supervision) does anyone know if the guidelines for the 2 day contact have changed? Our pharmacist is wondering if this is a service they can take over for the MD office. My orginial stance was due to direct supervision it had to be someone in the MD's office making that contact but now I am unsure.
Any thoughts? How are things being done in other locations?
Thanks
Tara
 
TCM and CCM are two very different services. To my knowledge, nothing has changed with regards toTCM.

CCM is used to report chronic care management services (as performed within a Care Management program staffed by RNs, LPNs, etc.) in the practice setting. Incident-to guidelines have been changed for this service only (general supervision), so the provider does not need to be present in the office when care mangement services such as medication reconciliation, care planning, or care coordination is taking place.

The Final Rule has a very lengthy but detailed explanation of what is expected to bill CCM---which has requirements that are not in CPT and could get you in hot water if you don't understand them. Research carefully.
 
You are correct that CMS did remove the requirement for direct supervision for TCM services in addition to CCM.

"After consideration of the comments, we are finalizing our proposal to revise our regulation at ? 410.26, which sets out the applicable requirements for ‘‘incident to’’ services, to permit the CCM and non-face-to-face portion of the TCM services provided by clinical staff incident to the services of a practitioner to be furnished under the general
supervision of a physician or other practitioner."

However, this did not change the other requirements for "incident to" services that still do apply to TCM and CCM. This means all elements of the TCM service would have to be furnished by staff who are direct or leased employees or independent contractors of the practice.

Would also consider if there are anti-kickback or other regulatory concerns with proposed service.

Hope that helps.
 
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