Wiki Question about billing for chronic care management services using a third party vendor

MagenD

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I'm not sure if many people out there have experience with this, but I am doing billing for a practice who has recently started using a third party vendor to offer chronic care management services. I have come across several patients that this company is billing the doctor for but when I go look into the documentation for the month, it only says they left several voicemails but never in the course of that month did they actually speak with the patient. Can this still be billed to insurance? I don't know a lot about ccm as this is all new to me, but my gut is saying no, this shouldn't be billed as the patient never really received any service that month. But I could be wrong.... Thanks for your help in advance!
 
Chronic care management coding/billing is based on the total time spent by the provider and/or clinical staff for the entire month. The time spent calling a patient and leaving a message could be counted toward this time tp meet the threshold for billing a charge, but it is only one component of the service and all of the rest of the requirements of the service would also have to be in place. Third party vendors who offer this service usually understand these requirements pretty well - you might wish to have a conversation with them about where to look in the records to ensure that the necessary documentation to support the charges is present.

Here is a good guide to the CMS requirements for billing chronic care management services:

 
"Obtaining advance consent for CCM services ensures the patient is engaged and aware of applicable cost sharing. It may also help prevent duplicative practitioner billing. A practitioner must obtain patient consent before furnishing or billing CCM. "

You cannot obtain consent if you have not spoken to the patient. You don't get credit for an hour of time if you spend one minute, on sixty different occasions leaving messages.

Also, can you even farm this out to a third party? The guidelines talk alot about the "billing provider" and what has to be performed by them personally.
 
"Obtaining advance consent for CCM services ensures the patient is engaged and aware of applicable cost sharing. It may also help prevent duplicative practitioner billing. A practitioner must obtain patient consent before furnishing or billing CCM. "

You cannot obtain consent if you have not spoken to the patient. You don't get credit for an hour of time if you spend one minute, on sixty different occasions leaving messages.

Also, can you even farm this out to a third party? The guidelines talk alot about the "billing provider" and what has to be performed by them personally.
I agree, it doesn't make sense to bill for leaving voicemails, which I've already told the practice manager about. Also, I did find an FAQ from 2010 through CMS that states that a,third party company can perform some part of ccm services, such as following up with patients but it still assumes that at least 15 minutes of work are being doing by the physician themselves, like care plan oversight, etc. They described it as incident-to billing when you use a chronic care management vendor. Its all pretty complex, to be honest.
 
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