Wiki TCM Coding and definition of clinical staff

[johnnalynn]

I work for a teaching facility and our physicians are wanting to perform transitional care management at the hospitals Outpatient Care Center. Staff at the patient center is employeed by the hospital, while the physicians are employeed by the university. I do not believe the hospital staff fits the criteria to make the phone calls for TCM services because they are not employeed by the physician. Just looking for guidance to see if anyone agrees/disagrees with this! Thanks

 

[thomas7331]

If the clinical staff are employed by the hospital, the hospital would bill the TCM services on the UB and be reimbursed by Medicare under OPPS - it would not be billed under the physician credentials. Here's a good reference from CMS that addresses this and other questions (for services performed in an outpatient hospital setting, see the section beginning on page 7):

https://www.cms.gov/Medicare/Medica...ent-Chronic-Care-Management-Services-FAQs.pdf

 

[johnnalynn]

Do the same Rules apply for TCM as well as CCM? the physicians are asking for something in black and white the at tells them they cannot bill TCM, we are not currently billing for CCM

 

[thomas7331]

Sorry, my mistake, I misread your original question and thought you were talking about CCM and got the two mixed up. TCM does involve physician work since there is a component of medical decision making. Your physicians should be able to bill for this in the hospital if they are documenting appropriate the components of the service that they personally perform. The claim would be split like any other E&M service performed in the hospital setting - the hospital would be paid under OPPS to reimburse for the services performed by the hospital staff. The physicians will receive a reduced rate under the Part B physician fee schedule since they are not paid for any incident to services in the facility setting. The same would actually apply for CCM if the documentation supported that some of the service was personally performed by the provider. It's only when a service is 'incident to' that it cannot be billed by a physician in a hospital.