CMS Releases Proposed Policy Changes for 2020

On July 29, 2019, CMS released its proposed changes for Chronic Care Management  2020. Here’s IQVIA’s Healthcare Technology take on the changes.

Overall there are some great new rules that we think our healthcare clients will really like.

  1. Chronic Care Management (CCM):

Currently, CCM bases its time on three codes:

  • CPT 99490 for 20 minutes of CCM time
  • CPT 99487 for 60 minutes of Complex CCM time
  • CPT 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 (CPT 99490), the proposal is to replace it with two new General Care Management codes (G-codes).

  • GCCC1:  20 minutes of initial clinical staff time per month pays $42 (same as CPT 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.  When reaching 60-minutes, it might make sense to bill the Complex Chronic Codes (if appropriate).

Healthcare COE Feedback: This change is great news. For many years, the industry has felt the gap between 20 and 60 minutes was too large. This give practices the opportunity to continue engaging the patient after 20 minutes.

  1. Principle Care Management (PCM):

We all know that CCM requires at least two chronic conditions. But what about the patients who have a single, serious and high-risk condition?  As of 2020, this proposal will create a new program called PCM. Except for the conditions, the requirements are like CCM.  The proposal would add:

  • GPPP1:  30 minutes of physician time per month – one complex chronic condition
    (Pays $74.24)
  • GPPP2:  30-minutes of clinical staff time per month – one complex chronic condition
  • (Pays $42 ~ same rate as 99490)

Healthcare COE Feedback:  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.

  1. 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 two significant 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 are furnished under General Supervision rather than the currently required, direct Supervision.

Healthcare COE Feedback: The industry has been eagerly anticipating the change to General Supervision. With this change, our Third-Party clinical partners can now offer RPM services to practices. The additional 20 minutes of RPM code are a surprise. RPM will be an important change in 2020.

  1. Transitional Care Management (TCM):

While there are no significant changes to this program, there are two impactful 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 rule to be announced in November.

Healthcare COE Feedback: It is good to see the TCM reimbursement rates increase. This is an underutilized program that adds significant value to the patient. We’re excited to see increased payments and relaxed restrictions.

2020 proposed changes

The changes proposed by CMS will affect payment policies, payment rates, and quality provisions for services furnished under Medicare Physician Fee Schedule (PFS) on or after January 1, 2020.

CMS said the calendar year (CY) 2020 PFS proposed rule is one of several proposed rules that reflect an Administration-wide strategy to create a healthcare system that results in better accessibility, quality, affordability, empowerment, and innovation.

To learn more about the IQVIA’s Healthcare Technology practices, please reach out to the following practice leads:

Chris McShanag, vice president, population health and provider solutions.

Ted Marsh, vice president, strategic planning and digital healthcare practice.

Steve Schneiderman, vice president, payer technology and operations.

Justin Washburn, vice president, healthcare data management.

Adam Mariano, vice president, health innovation.