CMS Proposed Care Management Payments for 2015 and Beyond Update

2015 CMS Chronic Care Payment The Timeline and History July 2013 – Originally described in Federal Register (for payment beginning in 2015) September 2013 – MiPCT and many other groups submitted comments November 27, 2013 – CMS issued responses July 2014 – CMS likely to issue proposed final rule in Federal Register with opportunity to comment November 2014 – Final 2015 rules likely to be issued (with final provisions)

2015 CMS Chronic Care Management Purpose/Intent To recognize the role and importance of non face-to-face care management work To support care management in primary care that contributes to better health and reduced expenditure growth To “appropriately value” care management in fee schedule

Recap of the CMS Chronic Care Revised Proposed Rules (Nov 2013) AreaOriginally ProposedNov 2013 Revised Proposed Rule Conditions Covered“Complex” (2 or more chronic conditions that place the patient at significant risk of death…or functional decline Same (but now called “chronic” instead of “complex”) Staff Requirements to Provide Care Management Required NP/PA employed by practice in addition to physician CMS will consider removing NP/PA requirement and expanding employment options PCMH DesignationSuggested NCQA and other national designations and requested comment CMS will consider other options

Recap of the CMS Chronic Care Revised Proposed Rules (Nov 2013) – Cont. AreaOriginally ProposedNov 2013 Revised Proposed Rule EHRs and Meaningful UseRequire EHR that meets Meaningful Use standards CMS will consider easing requirement BillingTwo quarterly G Codes (Initial, Subsequent) CMS to consider one monthly CPT Code Patient Consent (Affirmation to Care Management) Require initially and reaffirm annually Require initially; No need to reaffirm unless change in provider Annual Wellness VisitRequired AWV or IPPE prior to billing for chronic care management Recommend (not require) AWV or IPPE prior to billing (but allow care management initiation during AWV or IPPE)