CMS states it wants to increase pay to primary care physicians. And while we might quarrel with their strategies or with the speed of achieving the goal, few would quarrel with the goal itself.
In recent years, CMS has developed HCPCS codes and adopted CPT® codes, some limited to primary care and some not specialty restricted, but all likely to be reported by primary care practices.
Meanwhile, although payment systems are moving to outcome and value measures, the revenue for most primary care practices continues to be fee-for-serviced based, and alternate payment models (APM) are built on top of fee-for-service.
Some of the new services defined by CPT® HCPCS codes haven’t pleased primary care physicians, either because of the definition of the services or the payment for them.
Working with and listening to primary care physicians, I think that some of these services can be embraced and some should be ignored, for the time being. I’m an advocate of implementing Medicare Wellness Visits and transitional care management services into primary care and setting aside chronic care management for most practices. Advance care planning will be relevant in selected practices, but not all. And many other prevention services just don’t pay enough.
There can be significant variation in work RVUs per encounter (or revenue per encounter) within a group. I reported on this in an article in Family Practice Management. When I look at this variance, some of it comes from differences in level of service reporting, but more is from the use of wellness visits and transitional care management.
Thumbs up to wellness visits and problem visits at the same encounter
Some physicians objected to the definition of the Welcome to Medicare and initial annual and subsequent annual wellness visits (AWV) because there was no required physical exam. These visits don’t prohibit doing an exam. The Welcome to Medicare and initial wellness visit have high work RVUs and payment.
Medicare allows a physician to bill a problem oriented visit on the same day, as long as the documentation for the wellness visit isn’t used to select the level of problem oriented visit. The wellness visits don’t require HPI, ROS, exam or assessment and plan of a problem.
When I review documentation, I find that many of these visits document the requirements of the wellness visit and the key components of a problem-oriented visit.
In practices that have implemented the wellness visits successfully, staff members collect and record the data for the wellness visit, and the physician or non-physician practitioner (NPP) documents the personalized prevention plan and, if relevant, the problem-oriented visit.
Of course, both must be documented—describe the status of the patient’s chronic diseases in the HPI, do an exam and note the assessment and treatment at the end of the note. Reporting wellness visits and when relevant, wellness visits and problem-oriented visits on the same day is good for the patient and good for the practice.
Thumbs up to transitional care management (TCM)
Primary care practices are already managing the transition for hospitalized patients to home, and getting paid only for the office visit.
TCM allows the group to be paid for the work the physician, NPP and staff are already doing. It requires a phone call to the patient in two business days, a visit in 7 or 14 days (depending on the code), reviewing the discharge summary and medication reconciliation.
It is not for every discharge. It is for patients who need additional non-face-to-face support by the medical and clinical staff in the transition to home. It has high work RVUs and reimbursement.
CMS changed the rules January 1, 2016 allowing the visit to be billed on the day of the E/M office visit, rather than waiting 30 days from the date of discharge. This is a definite yes: get paid for the work the practice is now doing for free.
Thumbs up, equivocally, to chronic care management (CCM)
CMS has eased the restrictions on billing CCM services and changed the consent requirement from written to verbal. Performing these services requires clinical staff and a software module that tracks time and activities. There are chronic care management codes for staff work, and one for physician/NP/PA work. If you are considering these, or performing them, be sure to download the CodingIntel Care Management Coding Guide.
CMS continues to believe that more patients are eligible to receive these services than are being provided, but many primary care groups find them difficult to implement.
Thumbs up to advance care planning (ACP)
Beginning in 2016, physicians and NPPs can be paid for discussion of end of life issues with patients and/or family members.
- 99497 Advanced care plan 30 minutes
- 99498 additional 30 minutes
Since coding is through the looking glass, a clinician must meet over half of 30 minutes, 16 minutes, to bill for the service. That’s a long time for a service in the office. It can be billed with an office visit, but the time of the office visit and the time of the ACP can’t be double counted.
When I think it will be useful is for a patient’s family member who wants to come in to discuss a change in the patient’s condition and long term plans. Or, for a physician and family member of a hospitalized patient. After rounding in the morning, a physician could have a discussion with a family member in making end of life decisions.
This isn’t a code that can be used every day of a hospitalization, but when the patient’s condition changes and warrants the discussion.
When it is done on the same day a wellness visit and submitted with modifier 33, there is no co-pay or deductible. But, it might be difficult to perform on the day of a wellness visit because the wellness visit is time consuming on its own.
Watch Betsy’s 60 minute on-demand webinar “Care Management Services” for a review of the coding rules as well as tips for doing, and documenting care management services. Webinars are free for members. Not a member? Find out how you can watch too!
Thumbs down to HCPCS codes with low RVUs
CMS is required to cover any service that the USPSTF gives an A or B rating. But, that doesn’t mean they have to pay adequately for the service.
If you download the CMS preventive medicine chart, you’ll see some of these services.
- G0442 screening for alcohol misuse, 15 minutes.
Even using the CPT® rule of meeting over half of the threshold, does alcohol screening take 8 minutes? And the payment is under $20.
- G0444 Annual depression screening, 15 minutes
Annual depression screening is reported with code G0444, also a 15 minute code. The patient filling out the PHQ9 doesn’t take 8 or 15 minutes, and it also has a payment rate of under $20.
- G0447 Face-to-face behavioral counseling for obesity, 15 minutes
15 minutes of behavioral counseling for obesity, G0447, has a slightly higher reimbursement rate. Of course, practices will screen for alcohol misuse and depression, but the HCPCS G-codes will probably not describe the service that was performed.
If your primary care practice hasn’t adopted the wellness visits and TCM, I urge you to take a second look at implementing them. Both AAFP and ACP have resources that will help.
Since I wrote this article, CMS has added payment for non-face-to-face prolonged services, for behavioral health integration, for an initiating visit before CCM and for a cognitive assessment.
You can find coding resources for those services here on CodingIntel by entering a keyword or code in the search box.