Society Advocacy Leads to CMS Policy Change on Care Coordination/Behavioral Health

Earlier this month the Centers for Medicare & Medicaid Services (CMS) released updated guidance for billing Chronic Care Management (CCM) Services. That guidance provided key improvements on 2017 billing of three codes for CCM services with payment ranging from $43 to $141, depending on the complexity of the patient’s needs. The Society has now confirmed with CMS that the agency has clarified their position and will reimburse for these codes for services furnished in both skilled nursing facilities (SNF) and nursing facilities (NF). Previous guidance indicated that the codes would only be reimbursed in the NF setting. “The Society was instrumental in getting CMS to conclude that CCM codes were appropriate for practitioners in the SNF/NF”, says Charles Crecelius, MD, PhD, CMD, Society Past President and current Chair of the Payment and Practice Management Subcommittee. Alex Bardakh, MPP, Society Director for Public Policy and Advocacy, cautions that practitioners must carefully review and understand all the requirements of these codes as CMS will likely review their use and impact on the Medicare program. As the Society and a broad coalition of stakeholder groups argued for the last several years, the intention of these codes is to provide reimbursement and incentives for vital services that improve patient care through care coordination which has been proven to improve health outcomes and reduce Medicare costs.

In addition, CMS has also confirmed with the Society that for the new 2017 behavioral health care management codes, time could be counted regardless of location of the patient for some or all of the service period. In the final rule for CY2017, CMS approved three codes (G0502, G0503, G0504) which apply to care provided under the psychiatric Collaborative Care Model (CoCM) by a primary care team consisting of a treating physician or other qualified health care professional (e.g., a nurse practitioner (NP) or physician assistant). There are additional codes for General Care Management for Behavioral Health Conditions (GO507) and Assessment and Care Planning for Patients with Cognitive Impairment (G0505).

For more source reference documents on the new codes please click here.

The Society will continue to work with CMS to develop materials for practical examples on billing these codes. If you are currently using any of these codes for your SNF/NF practice please e-mail us at publicpolicy@paltc.org.