CMS Proposes Important Change to CCM in RHC and FQHCs

07/18/16  Portland, Ore.

With these proposed changes, it will be easier for RHC and FQHCs to participate meaningfully in the CCM program.

Beginning on January 1, 2016, RHCs and FQHCs could receive an additional payment for the costs of Chronic Care Management (CCM) services that are not already captured in the RHC All-Inclusive Rate (AIR) or the FQHC PPS for CCM services to Medicare beneficiaries having multiple (two or more) chronic conditions. RHCs and FQHCs can bill for CCM services when a RHC or FQHC practitioner furnishes a comprehensive evaluation and management (E/M) visit, Annual Wellness Visit (AWV), or Initial Preventive Physical Examination (IPPE) to the patient prior to billing the CCM service, and initiates the CCM service as part of this visit. CMS also required that these services be provided under DIRECT level of practitioner supervision for RHC and FQHCs. NRHA objected to this higher level of supervision as being unnecessary and inhibiting these clinics from providing needed care to Medicare beneficiaries in rural areas.

CMS released the annual Physician Fee Schedule (PFS) proposed rule on July 6, 2016 and changed the supervision requirement. Simply put, the proposed rule changes the supervision requirement in a RHC or FQHC from direct to general levels, meaning that CCM activities may be furnished using ancillary personnel without a practitioner being in the same building. Here is the relevant excerpt from the proposed rule:

To enable RHCs and FQHCs to effectively contract with third parties to furnish aspects of CCM and TCM services, we propose to revise §405.2413(a)(5) and §405.2415(a)(5) to state that services and supplies furnished incident to TCM and CCM services can be furnished under general supervision of a RHC or FQHC practitioner. The proposed exception to the direct supervision requirement would apply only to auxiliary personnel furnishing TCM or CCM incident to services, and would not apply to any other RHC or FQHC services. The proposed revisions for CCM and TCM services and supplies furnished by RHCs and FQHCs are consistent with §410.26(b)(5), which allows CCM and TCM services and supplies to be furnished by clinical staff under general supervision when billed under the PFS.

There are other changes to the CCM benefit that will ease the administrative burden to conduct CCM services. These changes are found starting on page 183 of the proposed rule. These include the Initiating Visit, clarifying the 24/7 access to care requirement, care plan availability simplification and easing the care transitions requirement.

NRHA urges members to offer these services in your clinics as well as conducting AWVs. NRHA will be commenting favorably to these proposed changes in our comment letter which is due September 6, 2016. If you have any questions or need additional information, please let them know.