CMS Proposed Care Management Payments for 2015

and Beyond

Update

2015 CMS Chronic Care PaymentThe Timeline and History

• July 2013 – Originally described in Federal Register (for payment beginning in

2015)• September 2013

– MiPCT and many other groups submitted comments • November 27, 2013

– CMS issued responses• July 2014

– CMS likely to issue proposed final rule in Federal Register with opportunity to comment

• November 2014 – Final 2015 rules likely to be issued (with final provisions)

2015 CMS Chronic Care Management Purpose/Intent

• To recognize the role and importance of non face-to-face care management work

• To support care management in primary care that contributes to better health and reduced expenditure growth

• To “appropriately value” care management in fee schedule

Recap of the CMS Chronic Care Revised Proposed Rules (Nov 2013)

Area Originally Proposed Nov 2013 Revised Proposed Rule

Conditions Covered “Complex” (2 or more chronic conditions that place the patient at significant risk of death…or functional decline

Same (but now called “chronic” instead of “complex”)

Staff Requirements to Provide Care Management

Required NP/PA employed by practice in addition to physician

CMS will consider removing NP/PA requirement and expanding employment options

PCMH Designation Suggested NCQA and other national designations and requested comment

CMS will consider other options

Recap of the CMS Chronic Care Revised Proposed Rules (Nov 2013) – Cont.

Area Originally Proposed Nov 2013 Revised Proposed Rule

EHRs and Meaningful Use Require EHR that meets Meaningful Use standards

CMS will consider easing requirement

Billing Two quarterly G Codes (Initial, Subsequent)

CMS to consider one monthly CPT Code

Patient Consent (Affirmation to Care Management)

Require initially and reaffirm annually

Require initially; No need to reaffirm unless change in provider

Annual Wellness Visit Required AWV or IPPE prior to billing for chronic care management

Recommend (not require) AWV or IPPE prior to billing (but allow care management initiation during AWV or IPPE)