Chronic Care Management does not have to be provided by direct employees of the billing provider. Providers can make use of “incident to” billing to claim CPT 99490 even if the care coordinator providing CCM services does not work in the same facility, but the care coordinator does have to meet the minimum clinical staff requirements.
The Centers for Medicare and Medicaid Services (CMS) stated in their CY 2015 Physician Fee Schedule Final Rule:
CCM services could be furnished ‘‘incident to’’ if the services are provided by clinical staff under general supervision of a practitioner whether or not they are direct employees of the practitioner or practice that is billing for the service… it does not matter whether the practitioner is directly available to supervise because the nature of the services are such that they can be, and frequently are, provided outside of normal business hours or while the physician is away from the office during normal business hours.
CPT 99490 / Chronic Care Management contrasts from many programs where direct supervision is required. Under direct supervision, the supervising practitioner must be present in the office suite and be immediately available to provide assistance and direction throughout the service (but does not mean that the supervising practitioner must be present in the room where the service is furnished).
General supervision and incident-to billing allows providers to contract with third-party Chronic Care Management vendors to provide full turnkey Chronic Care Management solutions.
