I am pleased to comment on the proposed Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2017 for doctors and other clinicians under Medicare. In the Notice of Proposed Rule making,published July 15, 2016 (CMS-1654-P), you seek comment on the implementation of changes to Medicare’s payments for care management services, including Chronic Care Management (CCM).
I strongly endorse the role of the payments for care management in the current fee-for-service system to support and incentivize practices to develop the care management infrastructure needed to succeed in the upcoming Advanced Alternative Payment Models (Advanced APMs). We encourage CMS to pursue the improvements proposed in this rule making to increase the provision of care management services.
With greater diffusion of advanced primary care, more can be accomplished.I support your proposals to
- Add CPT code 99487 – Complex chronic care management services to appropriately pay for care management for patients who require establishment or substantial revision of a comprehensive care plan,moderate or high complexity medical decision making, and 60 minutes of clinical staff time and to add CPT code 99489 – Each additional 30 minutes
The addition of this code will more appropriately pay for the time required for the initiation of CCM and the provision of CCM to more complex patients. The current code which reimburses for 20 minutes per calendar month is not sufficient to acknowledge the time it take to do the complex work of establishing the comprehensive care plan. These new codes will increase the provision of CCM by improving payment accuracy. The proposal to enhance the payment for face-to-face encounters to initiate CCM also acknowledges the front-loaded effort of initiating CCM and pays more accurately for the time and effort required to start patients on CCM.
I ask that CMS provide more clarity on the criteria to differentiate the appropriate use of the existing code 99490 from the new proposed code 99487. Guidance on what constitutes a “substantial” revision to a care plan and guidance on “moderate to high complexity medical decision making” will assist practitioners to code these services correctly.
I also support the waiver of the face-to-face encounter for established patients who have already had a qualifying face-to-face encounter with the billing practitioner in the past year. This change will have a substantial benefit in breaking the bottleneck of physician time to start CCM for their established patients with chronic conditions and needs which are already known to the practitioner, and quite possibly have been known for years. You are seeking comment on the whether a period of time shorter than one year would be appropriate. We believe that the proposed one-year period is appropriate because it is consistent with the time frame for Annual Wellness Visits and the time frame for many typical preventive services and the annual check-ups which are the basis for comprehensive E/M visits. A time frame shorter than a year would still disrupt the well-established annual care plans of many patients.
Finally, I wish to applaud the removal of the awkward requirement that written beneficiary consent be entered as part of the beneficiary’s electronic health record. This process adds unnecessary routines to the workflow of CCM initiation without adding patient or provider benefit. We agree that beneficiary consent is important and support the proposal that beneficiary consent can be documented in the medical record instead of obtaining a written agreement.
I look forward to engaging in the rule making process as the current and proposed codes for care management services are further developed in 2016.