CMS releases proposed policy changes for 2020
On July 29, 2019, CMS released their proposed changes for next year, 2020. We read the 1,700 page document so you don't have to. Here's our take on the changes: Overall there are some great new rules that we think our practices will really like.
1. Chronic Care Management:
Currently, CCM time is based on 3 different codes:
- 99490 for 20 minutes of CCM time
- 99487 for 60 minutes of Complex CCM time
- 99489 for each 30 minutes of additional Complex CCM time
For 2020, CMS is proposing adding new time categories for non-Complex CCM time (99490)
Instead of one 20-minute code (99490), the proposal is to replace it with 2 new G-codes.
- GCCC1: 20 minutes of initial clinical staff time per month - Pays $42 (same as 99490)
- GCCC2: Additional 20 minutes of clinical staff time per month Pays $31.25
With these new codes, spending 40 minutes of CCM time would pay around $73.52. CMS is still seeking feedback on whether GCCC2 can be billed multiple times. At the point when 60-minutes is reached it might make sense to bill the Complex Chronic Codes (if appropriate).
ThoroughCare's Feedback: We're very excited about this change. For years, we felt the gap between 20 and 60 minutes was too large. This will give practices the opportunity to keep engaging the patient after 20 minutes has been reached.
2. Principle Care Management (PCM):
We all know that CCM requires at least 2 chronic conditions. But what about the patients who have a single serious and high risk condition. As of 2020, this proposal would create a new program called PCM. Except for the conditions, the requirements are very similar to CCM. The proposal would add:
- GPPP1: 30 minutes of physician time per month - one complex chronic condition
- GPPP2: 30 minutes of clinical staff time per month - one complex chronic condition
- (Pays $42 ~ same rate as 99490)
ThoroughCare's Feedback: Another great change. Many patients have been missing out on CCM because they only have one chronic condition. In 2020, these patients can now be managed under PCM!
3. Remote Patient monitoring (RPM):
In 2019, CMS released new codes for RPM. CPT Code 99457 allowed for 20 minutes of clinical staff time during the month.
For 2020, there are 2 big changes:
- New Code for "additional 20 minutes of RPM time" - 994X0 (Pays: $26.31)
With this change 40 minutes of RPM time would pay: $77.85
- RPM codes 99457 and 994X0 can be furnished under General Supervision rather than the currently required, direct Supervision.
ThoroughCare's Feedback: Awesome! We've been eagerly anticipating the change to General Supervision. With this change, our 3rd party clinical partners can now offer RPM services to practices. The additional 20 minutes of RPM code was an unexpected surprise. RPM will be really big in 2020!
4. Transitional Care Management (TCM):
While there are no significant changes to the program itself, there are 2 great changes:
- Increased payment for TCM (proposed):
99495 (Moderate) = Increased to 2.36 work RVUs
99496 (Complex) = Increased to 3.10 work RVUs
- Evaluation of conflicting services:
- CMS is evaluating the list of services that are not payable in the same service period as TCM
- The expectation is that several services MAY become allowed in conjunction with an active TCM
- CMS is still seeking comment and we'll expect the final outcome to be announced in November.
ThoroughCare's Feedback: It's nice to see the TCM reimbursements increased. This is an underutilized program that adds significant value to the patient. We're excited to see increased payments and relaxed restrictions.
Overall, the 2020 proposed changes are much better than we hoped. Please note that these are still "proposed" and anything can change. The final changes for 2020 will most likely be published in 2020.
For our ThoroughCare practices, we'll be updating our software to support all of the new changes. If you haven't started doing RPM yet, sign up for a DEMO asap to see the new solution. RPM has incredible margins and is well-received by patients. Let us know if you have any questions or comments.