APA Supports New Complex Chronic Care Management Codes

APA is endorsing the government’s move toward incorporating “complex chronic care management codes” as part of the Medicare fee schedule for 2014.

In response to a proposed rule issued by the Centers for Medicare and Medicaid Services (CMS) in August, then-APA Medical Director James H. Scully Jr., M.D., told CMS in a letter that the codes can create a means for compensating physicians for non-face-to-face services they provide to patients with complex chronic conditions.

(The proposed rule by CMS was issued in August and addresses a variety of regulatory and payment policy issues, but does not include the 2014 fee schedule; a final rule, with the fee schedule, is expected this month. Look to Psychiatric News for coverage.)

“APA strongly favors compensating physicians for the non-face-to-face care management, including, but not limited to, team conferences, telephone calls, and patient education they provide to Medicare beneficiaries suffering from chronic care conditions,” Scully wrote. “We commend CMS for moving in this direction, which we believe is a starting point. These codes cross an important barrier in not requiring face-to-face time. We support CMS’s proposal to utilize the parameters described in the CPT guidelines to identify patients eligible for complex chronic care condition management services. A disproportionate share of Medicare beneficiaries suffering from two or more chronic conditions are suffering from a mental illness as shown in CMS’s analysis of Medicare claims for patients with multiple chronic conditions.”

But Scully also said that the conditions currently required for billing the newly proposed complex chronic care management service G codes are unlikely to capture the non-face-to-face care management work many psychiatrists are performing for some of Medicare’s most chronically ill beneficiaries.

“Among the population of Medicare beneficiaries who comprise the severely and persistently mentally ill, our members often function additionally as primary care physicians, coordinating all or most of this population’s health care,” he wrote. “We urge Medicare to design complex chronic care management codes that our members can use when coordinating the health care of the chronically mentally ill Medicare population. This necessitates the design of complex chronic care management codes that have broader conditions of use, such as the two existing non-face-to-face CPT codes. We prefer the CPT codes because their use permits use of CPT guidelines and, consequently, other payers’ likely adoption of these codes.”

Scully also expressed support for the adoption of the psychiatry CPT values, reviewed and approved earlier this year by the Relative Value Update Committee (RUC) for the 2014 Fee Schedule.

“Adoption of the RUC recommended values is necessary to correct the current rank-order anomaly that exists between the psychiatric diagnostic evaluation with medical services (90792) and the psychiatric diagnostic evaluation (90791), which does not include medical services,” Scully wrote in a September 5 letter to CMS. “A disparity in payment was created by the adoption of RUC-recommended reductions in practice expense values for only 90792. The inequitable result of this is that psychiatrists and advance practice nurses have been paid less this year for doing more work with more complex patients. We believe this inequity created inappropriate incentives on the clinical level. This issue will be resolved if CMS adopts the RUC recommended practice expenses for the 90791.”

Scully also urged the government to adopt new values for CPT codes for psychiatric services, as recommended by the RUC.

Other issues Scully addressed included proposed rules around telehealth, liability for overpayment, quality measures, and the Medicare Physician Quality Reporting System. ■

Scully’s letter to CMS is posted at http://www.psychiatry.org/advocacy--newsroom/advocacy/9e9023b8-d3da-4c85-a2a2-c02fa8cbad9a.