General Surgery Coding Alert

Reader Question:

Determine 'Clinical Staff' Eligibility for TCM

Question: I work in a general surgery office and have some questions concerning codes 99495-99496 (Management of transitional care services…). Can we use these codes in our office as a billable service by “clinical staff,” and if so, who is considered “clinical staff”?

New York Subscriber

Answer: The Transitional Care Management (TCM) codes require one face-to-face visit with a physician or qualified healthcare provider, but the “clinical staff” can and probably will provide the rest of the services, either in the clinic or possibly in the hospital. These services often include some monitoring services, phone calls, assistance in setting follow up appointments or getting follow-up testing, etc. All of these services help to make to the “complexity” that helps to determine the level of code that you can bill.

Regarding the definition of “clinical staff,” the introduction to the CPT® manual provides definitive direction under the heading “Instructions for Use of the CPT® Codebook.” Paragraph three describes qualified healthcare providers as well as clinical staff. In general, clinical staff are nurses, medical assistants, nursing assistants, techs and other staff who cannot bill under their own provider numbers.