CMS proposes Chronic Care Management rule changes to increase access and reduce administrative burden

Posted by Steve Burrill, Partner, National Health Care Providers Advisory Leader, Deloitte & Touche LLP and Ryan Haggerty, Deloitte Advisory senior manager, Deloitte & Touche LLP on August 31, 2016

On Friday July 15, 2016, the Centers for Medicare and Medicaid Services (CMS) released its Proposed Rule for the Calendar Year 2017 Medicare Physician Fee Schedule, which outlines changes to Chronic Care Management (CCM). These changes are significant and seek to provide increased reimbursement for patients that require greater levels of medical decision making, attempts to reduce administrative burden, while also aligning CCM more closely to the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).1,2

In 2015, a new CPT code, 99490, was introduced that permitted health care providers to bill for managing the chronic conditions of Medicare patients.  Payment for this new code is intended to increase the coordination of care for beneficiaries with two or more chronic conditions.3 CCM allows providers to bill separately for these services, which carries the potential for a new revenue source. But in 2015, only 275,000 out of over 50 million unique Medicare beneficiaries received CCM services. The allowed charges under this code totaled $37 million.4

Under the proposed rule for 2017, there would be three new codes for CCM, and the requirements for receiving payment for these services would change. The new codes would allow for greater reimbursement for providing complex CCM services, while proposed modifications to current billing and technology requirements would reduce the administrative and operational burden associated with providing CCM services.

These proposed changes reflect an effort by CMS to integrate CCM more fully with health care organizations’ population health strategies and value-based care objectives. As provider groups continue to offer care management services, it is important for health care executives to consider CCM as a core component of improving quality of care for chronically ill populations and receive reimbursement for those efforts.1

As provider organizations assess their capabilities for designing and implementing CCM programs, they should consider what it will take to make those programs not merely operational, but also nimble: What are the technological, human capital, clinical documentation, and compliance requirements they must satisfy to manage these patient populations efficiently while they continue to respond to the changing landscape of value-based care?

If you have any questions on how we can assist you assess your readiness to develop or implement a CCM program, please contact Steve Burrill or Ryan Haggerty.

1Calendar Year 2017 Medicare Physician Fee Schedule (CMS 1654-P).
2Section 103, Medicare Access and CHIP Reauthorization Act of 2015.
3CMS Medicare Learning Network CCM Publication ICN 909188.
4Page 168, Calendar Year 2017 Medicare Physician Fee Schedule (CMS 1654-P).

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