EM Coding Alert

In E/M Coding Alert volume 8 issue 6, we offered a comprehensive guide to chronic care management (CCM) or complex CCM program management.

Almost a year later, things have changed for the better, according to our CCM experts. The 2021 CPT^® revisions to the descriptors and program guidelines for 99490 (Chronic care management services … first 20 minutes of clinical staff time directed by a physician or other qualified health care professional, per calendar month.), +99439 (… each additional 20 minutes of clinical staff time … per calendar month …), 99491 (Chronic care management services, provided personally by a physician or other qualified health care professional …), 99487 (Complex chronic care management services … first 60 minutes of clinical staff time directed by a physician or other qualified health care professional, per calendar month), and +99489 (… each additional 30 minutes of clinical staff time … per calendar month …) have made coding for CCM and chronic CCM a whole lot easier.

Here’s how.

First, Remember Some CCM Elements Haven’t Changed …

The core components of CCM have not changed. In order for a patient to be enrolled in a CCM program, the patient must still have:

• Two or more chronic conditions expected to last at least a year or until the patient’s death;
• Consented, either verbally or in writing, to CCM;
• An individualized care plan in an electronic medical record (EMR);
• Around-the-clock access to clinical staff;

… But Care Plan Guidelines Get Tweaked

Prior to the 2021 CCM changes, “the guidance for creating a care plan had been very specific and was somewhat of a barrier to even starting a formal CCM program,” according to Samuel L. “Le” Church, MD, MPH, CPC, CRC, FAAFP, AAFP, CPT^® Editorial Panel Advisor and one of the authors of the 2021 CCM code revisions. However, “the new guidelines for the care plan have evolved into more of a guide rather than a list of required elements, though there is still an expectation that the care plan is comprehensive,” Church adds.

This explains why the revised CPT^® guideline language stresses that the following elements are “typical” but “not limited to” a comprehensive care plan, and that they “are intended to be a guide for creating a meaningful plan of care rather than a strict set of requirements, so should be addressed only as appropriate for the individual”:

• Problem list.
• Expected outcome and prognosis.
• Measurable treatment goals.
• Cognitive assessment.
• Functional assessment.
• Symptom management.
• Planned interventions.
• Medical management.
• Environmental evaluation.
• Caregiver assessment.
• Interaction and coordination with outside resources and other health care professionals and others, as necessary.
• Summary of advance directives.

This also explains why CPT^® deleted the guideline that required the “establishment or substantial revision of a comprehensive care plan” for 99487. Instead, now you will only have to show your physician has “established, implemented, revised, or monitored,” the care plan for complex CCM. In other words, “no longer will you have to document a substantial care plan change in order to bill the code,” according to Mary I. Falbo, MBA, CPC, CEO of Millennium Healthcare Consulting Inc. in Lansdale, Pennsylvania.

New Code, Time Changes Reflect CCM Complexity

Another significant revision to the CCM service codes involves a change in the time parameters. Prior to 2021, 99490 only allowed you to bill for “at least 20 minutes of clinical staff time … per calendar month” per the old code descriptor. However, “many practices found that they spent far more than 20 minutes providing care management services,” according to Church.

“This is changed for 2021 with the addition of new code +99439, which permanently replaces temporary code G2058 [Chronic care management services, each additional 20 minutes of clinical staff time directed by a physician or other qualified health care professional, per calendar month …] for additional 20-minute increments, up to 2 units,” Church elaborates.

This means you can now bill for 60 minutes or more of clinical staff time spent on CCM, as the following table illustrates:

Hopefully, the change “will decrease the challenge of reporting complex chronic care management slightly,” Falbo notes.

CCM with TCM and Anticoagulation Management

One other significant change to CPT^® CCM guidelines now allows you to deliver and bill CCM in conjunction with 99495 (Transitional Care Management Services with … Medical decision making of at least moderate complexity …), 99496 (… with … Medical decision making of high complexity …), and 93793 (Anticoagulant management for a patient taking warfarin …).

Such “changes to the CCM rules should encourage program use rather than restrict,” Church believes. However, as the guidelines preceding the CCM codes note, care management activities performed by clinical staff, or personally by the physician or other qualified healthcare professional (QHP), typically include “management of care transitions not reported as part of transitional care management (99495, 99496).” So, “it is very important that the services delivered are not overlapping. That is, no double-dipping!” cautions Church.