CMS Announces Updates to TCM Billing Requirements

CMS Announces Updates to TCM Billing Requirements

By Stephen J. Canon, MD
The Centers for Medicare & Medicaid Services (CMS) recently announced an update to the way transitional care management (TCM) is billed. Although TCM is an important tool in reducing unnecessary hospital readmission rates, some of those who were utilizing TCM suggested that the requirements were confusing. As a result, CMS will change the date of service (DOS) requirement starting on January 1, 2016.
Previously, practices had to use the 30th calendar day after the patient’s discharge as the DOS to ensure the patient wasn’t readmitted within that 30-day window. This meant they usually had to wait a couple of weeks after the face-to-face visit to submit the bill for TCM. Starting January 1, the DOS will reflect the date of the face-to-face visit. That means that practices will have the option to bill for TCM much sooner.
Here’s the Catch
The catch is that practices will still have to track the patient through to the 30th calendar day to ensure they have not been readmitted. If the patient is readmitted within 30 days, and the practice has already billed TCM for that patient, they cannot bill for TCM when the patient is discharged the second time. If the patient is readmitted and the practice has not yet billed, they can wait until the patient is discharged the second time, track the patient for TCM, and bill after the second face-to-face visit.
Good News for Practices
The good news is that this update will allow a lot more flexibility on when practices can bill! However the initial contact and face-to-face visit requirements will not change, so ultimately this doesn’t have to change the way practices track and bill for TCM.
This also does not affect the way practices perform chronic care management (CCM). CCM still cannot be billed for in the same month as TCM except under specific circumstances. If the TCM service period ends before the end of a calendar month and at least 20 minutes of qualifying CCM services are subsequently provided during that month, a practice may bill for CCM.
Author bio:
Stephen J. Canon, MD, is a board certified urologist and associate professor at the University of Arkansas for Medical Sciences (UAMS). He is also chief of pediatric urology at Arkansas Children’s Hospital and program director of the UAMS Department of Urology. He is the co-founder of Phyzit TCM™, a cloud-based application which streamlines the TCM process to enable improvement of patient care following hospital discharge. His research interests include minimally invasive surgery in pediatric urology and the utilization of technology to improve patient care.

Michelle Dick
Follow me

About Has 256 Posts

Michelle A. Dick, BS, is a freelance content specialist, providing writing, editorial expertise, and graphic imagery to clients. Prior to becoming a free agent, she was an executive editor for AAPC, editor-in-chief at Eli Research, and editor at Element K Journals. After earning a Bachelor of Science from the State University of New York at Buffalo State, Dick entered the publishing industry as a graphic artist, ad coordinator, and web designer for White Directory Publishers, Inc.

9 Responses to “CMS Announces Updates to TCM Billing Requirements”

  1. Jamie Petricich says:

    Does this apply to: Dates of services after 1/1/2016, admit dates after 1/1/2016, or discharge dates after 1/1/2016. For example: If a patient is admitted in December, discharged in December, and their follow-up visit is in January, do we bill TOC on the January date of service or do we bill it as we would have in 2015?

  2. Judy says:

    Can you please provide the link to this information. I contacted Medicare and they are unaware of the any changes. They even provided me with the update link.

  3. Kelly Martinelli says:

    Will you please point me to the resource at CMS on the TCM billing update on the date of the visit? I have been looking but have not seen anything except for rural areas or critical access with TCM.

  4. Stephen Canon, MD says:

    Hi Judy and Kelly,
    In the “Medicare Program; Revisions to Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2016” which came out in November of 2015, they state that:
    “Regarding TCM services, we are adopting the commenters’ suggestions that the required date of service reported on the claim be the date of the face-to-face visit, and to allow (but not require) submission of the claim when the face-to-face visit is completed, consistent with current policy governing the reporting of global surgery and other bundles of services under the PFS. We will revise the existing subregulatory guidance for TCM services accordingly.” (80 FR 70921)
    You can find the exact response within the document by following the link below.
    I hope you find this helpful. Thank you for your comments and good luck with your TCM activities!

  5. Jana says:

    I am in agreement with Kelly, I cannot find anything specific on the CMS website. None of the information there indicates a change in how this is to be billed. The specific information page on TCM has not been updated since 2013 …….. please point me (us) to the resource so that we can correctly bill these codes …..

  6. Tina Holaday says:

    Same question as the others above, please provide link to CMS where these TCM changes for 2016 are verified. I am unable to find this.

  7. Tori says:

    The links provided lead back to the Federal Register where they state they are going to “adopt” comments regarding the allowance of billing the TCM codes at the time of the face-to-face visit. Please note, CMS has NOT adopted this, nor have they issued a Change Request. Until such time, I’m not leaning toward changing my reporting for TCM services. I feel this AAPC article is misleading by stating the change is from CMS.

  8. Roxana says:

    on the CMS website- not your MAC, go to the main page- search- type in transitional care. The first document that comes up is the PDF to the update.

  9. K says:

    How many days meets the requirement to bill a TCM? Like does 1 day meet the requirement?