March 17, 2016
7. Can I bill CPT 99490 for CCM services provided to beneficiaries in skilled nursing facilities,
nursing facilities or assisted living facilities?
If all the CCM billing requirements are met and the facility is not receiving payment for care
management services (for example, the beneficiary is not in a Medicare Part A covered stay),
practitioners may bill CPT 99490 for CCM services furnished to beneficiaries in skilled nursing
facilities, nursing facilities or assisted living facilities. The place of service (POS) on the claim
should be the billing location (i.e., wh
ere
the billing
pra
ctitioner would furnish a f
ac
e-
to-
face office visit with the patient) as per #5 above.
8. Is a new patient consent form required each calendar month or annually?
No, as provided in the CY 2014 PFS final rule (78 FR 74424), a new consent is only required if the
patient changes billing practitioners, in which case a new consent must be obtained and documented
by the new billing practitioner prior to furnishing the service.
9. Is Medicare now paying separately under the PFS for remote patient monitoring services
d
escribed by CPT code 99091 or similar CPT codes?
CPT
99091 continues to be bundled with other services for payment under the PFS. As per CPT
guidance, CPT codes 99090, 99091 and other
codes cannot be billed during
the
same service period as CPT 99490. However as discussed in the CY 2015 PFS final rule (79 FR 67727), analysis of
patient-generated health data and other activities described by CPT 99091 or similar codes may be
within the scope of CCM services, in which case these activities would count towards the minimum
20 minutes of qualifying
ca
re per month that are req
uire
d to bill CPT 99490. B
ut i
n
order to bill CPT
99490, such activity cannot be the only work that is done—all other requirements for billing CPT
99490 must be met in order to bill the code, and time counted towards billing CPT 99490 cannot also
be counted towards billing other codes.
10. If a physician arranges to furnish CCM services to his/her patients “incident to” using a
c
ase management entity outside the billing practice, does the billing physician need to ever see
the patient face-to-face?
Ye
s, as provided in the CY 2014 final rule (78 FR 74425), CCM must be initiated by the billing
practitioner during a “comprehensive” Evaluation & Management (E/M) visit, annual wellness visit
(AWV) or initial preventive physical exam (IPPE). This face-to-face visit is not part of the CCM
service and can be separately billed to the PFS, but is required before CCM services can be provided
directly or under other arrangements. The billing practitioner must discuss CCM with the patient at
this visit. While informed patient consent does not have to be obtained during this visit, it is an
opportunity to obtain the required consent. The face-to-face visit included in transitional care
management (TCM) services (CPT 99495 and 99496) qualifies as a “comprehensive” visit for CCM
initiation. Levels 2 through 5 E/M visits (CPT 99212 through 99215) also qualify; CMS is not
requiring the practice to initiate CCM during a level 4 or 5 E/M visit. However CPT codes that do
not involve a face-to-face visit by the billing practitioner or are not separately payable by Medicare
(such as CPT 99211, anticoagulant management, online services, telephone and other E/M services)
do not meet the requirement for the visit that must occur before CCM services are furnished. If the
practitioner furnishes a “comprehensive” E/M, AWV, or IPPE and does not discuss CCM with the
patient at that visit, that visit cannot count as the initiating visit for CCM.