Tucked deep within the 2022 Medicare Physician Fee Schedule proposed rule, presumably where it would be easy to miss, the Centers for Medicare & Medicaid Services (CMS) has penned a love letter to chronic care management.
While CMS may not directly state its adoration for chronic care management in the 2022 proposed rule, the agency proposes accepting RVS Update Committee (RUC) recommended update values for 10 codes in the chronic care management family. While that itself may not be unusual for a proposed rule, the justification includes language rarely used by CMS.
The agency states that it is proposing this payment update, which would significantly increase reimbursement for the 10 chronic care management CPT codes, because it is "consistent with our goals of ensuring continued and consistent access to these crucial care management services and acknowledges our longstanding concern about undervaluation of care management under the physician fee schedule."
To read CMS admitting that the physician fee schedule undervalues something is unusual — incredibly unusual. And that's significant. The proposed physician fee schedule is reviewed and dissected by many committees. By the end of this robust — and one might even say excessive — review process, the language included in the proposed rule tends to be non-committal and bureaucratic.
To now see CMS come out and blatantly assert that it is working to ensure access to chronic care management services, in part by increasing payments for the services, is a clear indication that the agency views CCM as an integral component of its long-term strategy.
Growing Support for Chronic Care Management
The proposed increase in reimbursement is just the latest way CMS has thrown its support behind chronic care management. In fact, in the 2022 proposed rule, CMS highlights a number of ways it has strived to support CCM in the past. These include the following:
- In the 2014 Physician Fee Schedule final rule, CMS finalized a separately payable HCPCS code for CCM, HCPCS GXXX1, to acknowledge that physicians and non-physician providers who furnish care to patients with multiple chronic conditions require greater resources than are required to support patient care in a typical E/M service.
- For 2015, CMS refined aspects of the existing chronic care management policies and adopted separate payment for CCM services under CPT 99490. This code requires a minimum of 20 minutes a month of CCM care. Under 99490, clinical staff supervised by a physician can perform CCM for billing purposes.
- For 2017, CMS adopted complex chronic care management (CCCM) CPT codes 99487 and 99489.
- In the 2019 Physician Fee Schedule final rule, CMS adopted new CCM CPT code 99491. This code reimburses physicians for performing 30 minutes of CCM care a month.
- In the 2020 final rule, CMS established payment for an add-on code to CPT code 99490. by creating HCPCS code G2058. CMS also created two new HCPCS G codes: G2064 andG2065.
- In the 2021 final rule, CMS finalized a replacement code for HCPCS code G2058: CPT 99439.
In the world of CMS, that's already a lot of love shown for chronic care management — more than most services get in a lifetime. But it doesn't stop there. For 2022 alone, CMS had added coverage for the following five new CPT codes:
- CPT 99X21 — Chronic care management services each additional 30 minutes by a physician or other qualified health care professional, per calendar month (List separately in addition to code for primary procedure)
- CPT 99X22 — Principal care management services for a single high-risk disease first 30 minutes provided personally by a physician or other qualified health care professional, per calendar month
- CPT 99X23 — Principal care management services for a single high-risk disease each additional 30 minutes provided personally by a physician or other qualified health care professional, per calendar month (List separately in addition to code for primary procedure)
- CPT 99X24 — Principal care management services, for a single high-risk disease first 30 minutes of clinical staff time directed by physician or other qualified health care professional, per calendar month
- CPT 99X25 — Principal care management services, for a single high-risk disease each additional 30 minutes of clinical staff time directed by a physician or other qualified health care professional, per calendar month (List separately in addition to code for primary procedure).
As CMS notes in the 2022 proposed rule, the chronic care management/complex chronic care management/principal care management (PCM) code family now includes five sets of codes, with each set including a base code and an add-on code. If the final rule solidifies the reimbursement increase, CCM will become one of the even more lucrative Medicare programs.
CMS Support of Chronic Care Management: Key Takeaway
While we might have been exaggerating a bit when we said CMS was declaring its love for chronic care management, it's clear that CMS views CCM as a service that provides significant value to patients and one that it has and will continue to support going forward.
Chronic care management is currently a valuable, revenue-generating service. The actions CMS has taken, both realized and proposed for now, for 2022 will only further enhance this value. If your practice isn't currently delivering CCM services, find out how easy it is to add chronic care management with Prevounce.