Only one in 10 beneficiaries relies solely on the Medciare program for healthcare coverage. The rest have some form of supplemental coverage to help with medical expenses, so 90% of your patients may not have to pay out of pocket for co-pays.

There is no specific guidance from CMS regarding required documentation. However, we would recommend that the following information be recorded and maintained for audit purposes:

• The total amount of time spent. Our TouchPoint system will provide documentation to the provider of the amount of time spent with each patient. The times are recorded and maintained in the system.

• The identity of the person providing service.

• A brief description of the services provided. P5 Connect, Inc. provides its clients with a detailed customized report of all services performed for each patient.

Again, CMS has not specifically required this level of documentation; this is, instead, a best practice to protect an organization in the event of an audit.

No, the total time billed in one month is 20 minutes of non-face-to-face time. Services cannot be applied towards future months.

The CCM services maybe furnished inside or outside the provider’s practice but with the providers general supervision. CMS general guidelines encompass a broad definition to ensure that CCM services are provided to a wider segment of the population. Clinical staff must perform these services under the general supervision of a physician. That physician, however, does not necessarily have to be the billing physician.

No, each physician is responsible for his / her own patient population.

P5 Connect, Inc. has created a Patient Consent Form that has to be discussed with the patient as part of a separate visit. The provider has to outline to the patient the services encompassed by CCM, how those services can be accessed, that only one provider can furnish CCM, that the health information will be shared for the purposes of service coordination, that the patient can revoke consent at any time, and that the beneficiary will be responsible for any associated co-pays.

Some MA plans are beginning to issue coverage consistent with CMS. It is unclear how MA plans with capitation or other shared risk arrangements will handle CCM, but we anticipate for service MA plans will reimburse in a fashion consistent with CMS.

Yes, specialists can bill for CCM.

There is no standard Care Plan required by CMS. However, the following components have been identified by CMS as appropriate components of the Care Plan:

• Problem list, expected outcome and prognosis, and measurable treatment goals;

• Symptom management and planned interventions, included all recommended preventative care services;

• Plan for care coordination with other providers;

• Medication management, including a list of current medications and allergies, reconciliation review of adherence and potential interactions, as well as oversight of patient self-management;

• Responsible individual for each intervention;

• Requirement of period review and revision;

Care Plans needs to:

• Provided to the patient and or caregiver;

• Must be documented in EHR;

• Made available to other team members furnishing CCM;

• Care plan must be available to caregivers 24/7;

• Note: Many of these responsibilities are already part of other programs such as Patient Centered Medical Home and Meaningful Use. For most providers that manage patients with two or more chronic conditions, these responsibilities are already part of the routine workflow.

CMS suggests that the documentation generated through an annual wellness visit is similar to the care plan. P5 Connect, Inc. will assist the provider with creating the Care Plan that meets the CMS guidelines.

CMS has stated the transmission has to be electronic. Facsimile transmission does not satisfy the requirement.

Patient portal is one of the ways to meet the CMS requirements. P5 Connect, Inc. through its partnership with TouchPoint Care, will allow patients to view their profile as well as their appointment schedule that will allow the provider to address and / or support CCM requirements that relate to the care plan and provider access.

“No EHR system … that exists on the market now logs time in that way and will automatically calculate it and give you a report,” notes Terry Mills, MD, FAAFP, director of patient care systems for Via Christi Health in Newton, Kansas. “If you’re doing it for a small number of patients you keep paper logs and track all the minutes. But then the return isn’t probably worth the hassle.” P5 Connect, Inc. will keep track electronically through its software, of all the time spent with each patient and will document the information gathered during that interaction.

• Transitional Care Management (CPT 99495) – there are instances where TCM and CCM may overlap in a way that would allow billing for both codes. P5 Connect, Inc. will offer additional guidance when requested to guide providers on this issue.

• Home Healthcare Supervision (HCPCS G0181)

• Hospice Care Supervision (HCPCS G0182)

• Certain end-stage Renal Disease (ESRD) Services (CPT 90951-90970)

At this point, CMS has indicated that there will not be automatic denials based upon date of service, site of service, or diagnosis codes. An automatic denial would occur if another provider already had been paid for CCM for the same beneficiary for the same time period. In the event of an audit, the CMS auditor would most likely look for signed consent form, an electronic care plan, and documentation supporting 20 minute so face-to-face time.