(Last Updated On: December 2, 2016)

Overall uptake of Chronic Care Management (CCM) in 2017 was slower than anticipated, with only 513,000 unique beneficiaries receiving the service by late fall of 2016. Uptake in Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs) was even lower due several of the limitations discussed in Decoding CPT 99490: Partnering for Chronic Care Management (CCM) in Federally Qualified Health Centers (FQHCs) and Rural Health Clinics (RHCs). Recognizing some of the root causes for the slow uptake for FQHC Chronic Care Management programs and RHC Chronic Care Management programs, CMS included as part of the 2017 Medicare Physician Fee Schedule changes:

To assure that CCM requirements for RHCs and FQHCs are not more burdensome than those for practitioners billing under the PFS [Physician Fee Schedule].

Below is a recap of the changes now approved for FQHC Chronic Care Management and RHC Chronic Care Management programs starting in 2017.

Changes for “Reducing Administrative Burden and Improving Payment Accuracy” for FQHC Chronic Care Management and RHC Chronic Care Management

Some of the general changes to Chronic Care Management as part of the 2017 Physician Fee Schedule (PFS) were also included as part of the changes for FQHC Chronic Care Management programs and RHC Chronic Care Management programs billing CPT 99490. See Table 1 below for a summary of the changes:

Table 1: Summary of FQHC/RHC Chronic Care Management Changes in 2017 

Change Overview Requirement Before Requirement After
Easing of face to face requirement Initiation into CCM requires face to face visit a provider Face to face visit is only required for new patients or patients that have not had a face-to-face encounter in the past 12 months
24/7 requirement can be met by auxiliary personnel (not necessarily direct access to practitioner) CCM services be available 24/7 with health care practitioners in the RHC or FQHC 24/7 access to a RHC or FQHC practitioner or auxiliary personnel with a means to make contact with a RHC or FQHC practitioner
Removal of 24/7 access of care plan Electronic care plan be available on a 24/7 basis to all practitioners within the RHC or FQHC whose time counts towards the time requirement for the practice to bill the CCM code Require timely electronic sharing of care plan information within and outside the RHC or FQHC, but not necessarily on a 24/7 basis
Allow faxing of care plans Care plan can be faxed only when the receiving practitioner or provider can only receive clinical summaries by fax Share care plan information electronically (can include fax)
Removal of certified EHR formatting of clinical summaries in care transitions Clinical summaries must be created and formatted according to certified EHR technology, and the requirement for electronic exchange of clinical summaries by a means other than fax RHC or FQHC creates, exchanges, and transmits continuity of care document(s) in a timely manner with other practitioners and providers
Easing of care plan copy given to patient requirements Copy of the care plan to be given to the patient or caregiver in written or electronic format Allows the care plan to be provided to the caregiver when appropriate (and in a manner consistent with applicable privacy and security rules and regulations)
Removal of consent form requirement Written agreement covering all the elements of beneficiary consent elements, and whether the beneficiary accepted or declined CCM services Document in the beneficiary’s medical record that all the elements of beneficiary consent were provided, and whether the beneficiary accepted or declined CCM services
Easing of format of communication to and from home community based providers Communication to and from home- and community-based providers regarding the patient’s psychosocial needs and functional deficits be document using a qualifying certified EHR Communication to and from home- and community-based providers regarding the patient’s psychosocial needs and functional deficits be documented in the patient’s chart

General Supervision of Clinical Staff to Allow Third Party Care Coordination

In 2016, FQHCs/RHCs were unable to contract with third parties to provide Chronic Care Management Services (see New Proposed Rule for General Supervision of Chronic Care Management (CCM) and Transitional Care Management (TCM) in FQHCs/RHCs). However, CMS noted that:

Since payment for CCM in RHCs and FQHCs began on January 1, 2016, some RHCs and FQHCs have informed us that, in their view, the direct supervision requirement for auxiliary personnel has limited their ability to furnish CCM services. Specifically, these RHCs and FQHCs have stated that the direct supervision requirement prevented them from entering into contracts with third party companies to provide CCM services, especially during hours that they were not open, and that they were unable to meet the CCM requirements within their current staffing and budget constraints

For this reason in 2017, CMS approved general supervision for FQHC CCM and RHC CCM programs so that these organizations can now contract with skilled care coordination companies to deliver effective and impactful Chronic Care Management programs:

We [CMS] are finalizing this policy to revise §405.2413(a)(5) and §405.2415(a)(5) to state that services and supplies furnished incident to CCM and TCM services can be furnished under general supervision of a RHC or FQHC practitioner

New Codes NOT Billable By FQHCs/RHCs

Although the 2017 PFS contained several changes that benefited FQHCs/RHCs, certain new care coordination codes are NOT yet available for FQHCs. These codes NOT available to FQHC Chronic Care Management  programs and RHC Chronic Care Managements include:

  • CPT 99487 – Complex chronic care management services first 60 minutes
  • CPT 99489 – Complex chronic care management services, each additional 30 minutes
  • CPT G0506 – Comprehensive assessment of and care planning by the physician or other qualified health care professional for patients requiring chronic care management service

FQHCs/RHCs would also not be eligible to bill for the new Behavioral Health Integration (BHI) codes including G0502, G0503, G0504, and G0507.

The FQHC Chronic Care Management changes and RHC Chronic Care Management changes in 2017 represent a strong step in the right direction, improving accessibility to valuable care coordination services to a largely underserved patient population and increasing the viability of Chronic Care Management programs for FQHCs/RHCs.