There were a number of significant changes affecting the delivery and billing of remote care management in the 2023 Medicare Physician Fee Schedule (PFS) final rule, as we covered in this webinar. One of them was the Centers for Medicare & Medicaid Services (CMS) finalizing the coverage for chronic pain management and treatment services (CPM) — new services that were introduced in the 2023 Medicare PFS proposed rule.
What to Know About Chronic Pain Management
Let's take a closer look at chronic pain management and what organizations considering adding CPM services to their remote care management program should understand before doing so.
To enroll patients in CPM, they must be experiencing persistent or recurrent pain lasting longer than three months. There does not need to be an established history or diagnosis of chronic pain. CPM can be initiated concurrently with the chronic pain diagnosis.
Initial visit requirement
The initial CPM visit must be in person and in a clinical setting.
Unlike the initial visit, subsequent CPM visits may be performed remotely/virtually. Although CMS speaks to CPM as if it was a care management service, the agency decided to designate CPM as a telehealth service for 2023. This means that the remote provision of CPM would follow the CMS telemedicine requirements versus the much more relaxed requirements of a "care management service." We expect there to be more clarity or adjustment to that point in future rulemaking.
To summarize, the delivery of chronic pain management services requires the following:
- overall treatment management, including the use of validated pain tools;
- person-centered care plan;
- medication management;
- pain and health literacy counseling;
- any necessary chronic pain-related crisis care; and
- coordination with other relevant practitioners, including available behavioral health support.
Clinicians are required to furnish all appropriate elements, but CMS acknowledged that not all elements will be appropriate for every beneficiary
Chronic pain management HCPCS codes
For 2023, there are two HCPCS codes associated with CPM: G3002 and G3003. HCPCS G3002 is for the first 30 minutes of CPM per month, with the requirement that the initial visit, as noted earlier, be conducted in person. HCPCS G3003 is for each additional 15-minute increment of CPM. It can be billed unlimited times each month, as medically necessary, once G3002 is satisfied.
The descriptors for G3002 and G3003 are as follows:
HCPCS G3002 — Chronic pain management and treatment, monthly bundle including, diagnosis; assessment and monitoring; administration of a validated pain rating scale or tool; the development, implementation, revision, and/or maintenance of a person-centered care plan that includes strengths, goals, clinical needs, and desired outcomes; overall treatment management; facilitation and coordination of any necessary behavioral health treatment; medication management; pain and health literacy counseling; any necessary chronic pain related crisis care; and ongoing communication and care coordination between relevant practitioners furnishing care, e.g. physical therapy and occupational therapy, complementary and integrative approaches, and community-based care, as appropriate. Required initial face-to-face visit at least 30 minutes provided by a physician or other qualified health professional; first 30 minutes personally provided by physician or other qualified health care professional, per calendar month. (When using G3002, 30 minutes must be met or exceeded.))
HCPCS G3003 — Each additional 15 minutes of chronic pain management and treatment by a physician or other qualified health care professional, per calendar month. (List separately in addition to code for G3002. When using G3003, 15 minutes must be met or exceeded.))
CMS noted that it believes these CPM HCPCS codes will "improve payment accuracy for these services, prompt more practitioners to welcome Medicare beneficiaries with chronic pain into their practices, and encourage practitioners already treating Medicare beneficiaries who have chronic pain to spend the time to help them manage their condition within a trusting, supportive, and ongoing care partnership."
Chronic pain management billing requirements
CPM services are furnishable and billable by physicians and non-physician providers (e.g., nurse practitioners, and physician assistants).
At this time, CMS has not restricted the number of physicians and non-physician providers who can bill CPM codes in the same month for the same patient. CMS stated it will be monitoring the program and considering whether to modify this lack of restriction if needed. In such instances when multiple providers are furnishing CPM services for the same patient, it would be prudent to coordinate care to better help ensure optimal treatment and support.
Both evaluation and management (E/M) and chronic pain management may be billed on the same day if all requirements to report each service are met and time spent providing CPM services does not represent time spent for providing any other reported service.
Billing with care management services
In the final rule, CMS acknowledge that the CPM services covered under HCPCS G3002 and HCPCS G3003 are distinct from other care management services (remote patient monitoring, remote physiologic monitoring, or remote therapeutic monitoring). CMS stated that CPM codes can be billed in the same month as other care management codes for the same patient. However, the same time must not be counted towards more than one care management code.
Chronic pain management reimbursement
CMS has elected to crosswalk the CPM relative value units (RVUs) to the principal care management (PCM) codes. HCPCS G3002 has a work RVU of 1.45 and HCPCS G3003 has a work RVU of 0.5. Note: At this time, reimbursement for G3002 and G3003 is unknown. When this information becomes available, we will update this post accordingly.
Chronic pain management for FQHCs and RHCs
CMS finalized the addition of CPM services to the existing federally qualified health center (FQHC) and rural health center (RHC) general care management code, HCPCS G0511. The payment rate for G0511 will continue to be average of national non-facility PFS payment rates for the FQHC and RHC care management and general behavioral health codes and PCM codes. G0511's payment will be updated annually based on PFS amounts for these codes, which is how updates are made currently.
Designation as "telehealth service"
In a surprising development, the final rule added a few services to the Medicare telehealth services list for 2023. This included chronic pain management and its two HCPCS codes. Any of the CPM in-person components included in HCPCS codes G3002 and G3003 may be furnished via telehealth, as clinically appropriate. CMS states this is intended to "increase access to care for beneficiaries."
Designating CPM as a telehealth service was an odd decision since, as we noted above, CMS speaks about chronic pain management as care management service. This decision raises a few questions:
- To deliver CPM, will providers need to follow the complex, federal telehealth rules and requirements currently waived during the COVID-19 public health emergency (PHE) once the PHE ends?
- Without the care management designation, outsourced clinical staff not in the same physical location as a physician cannot provide and bill CPM "incident to" a physician's services under "general supervision." Will this inability to tasks outsourced clinical staff with the provision of CPM stifle its usage?
CMS at least indicated its intention to reevaluate which facets of CPM could be performed by clinical staff and billed incident to the billing physicians.
Chronic Pain Management in 2023: A Mix of Good and TBD
The decision to finalize coverage for CPM is welcome and encouraging news. It further indicates that CMS views care management as an increasingly valuable and important mechanism for helping those with chronic diseases, including chronic pain, better manage their disease and reduce the need for costly urgent and emergent care. The finalizing of CPM follows other recent, significant and positive remote care management developments, including substantial increases in reimbursement for some chronic care management (CCM) services and the addition of new CCM CPT codes for 2022, the debut of remote therapeutic monitoring (RTM) in 2021, and the overhaul of RPM CPT codes and increase in their reimbursement for 2020.
While there's positive momentum behind chronic pain management, the decision to classify CPM as telehealth services rather than care management services is a potentially significant obstacle for adoption. We hope to see the barrier to usage addressed and receive further clarification on this exciting service in future PFS rules.
Health economic and reimbursement information provided by Prevounce is gathered from third-party sources and is subject to change without notice as a result of complex and frequently changing laws, regulations, rules, and policies. This information is presented for illustrative purposes only and does not constitute reimbursement or legal advice.
Prevounce encourages providers to submit accurate and appropriate claims for services. It is always the provider’s responsibility to determine medical necessity, the proper site for delivery of any services, and to submit appropriate codes, charges, and modifiers for services rendered. It is also always the provider’s responsibility to understand and comply with Medicare national coverage determinations (NCD), Medicare local coverage determinations (LCD), and any other coverage requirements established by relevant payers which can be updated frequently.
Prevounce recommends that you consult with your payers, reimbursement specialists, and/or legal counsel regarding coding, coverage, and reimbursement matters.
Payer policies will vary and should be verified prior to treatment for limitations on diagnosis, coding, or site of service requirements.
The coding options listed here are commonly used codes and are not intended to be an all- inclusive list. We recommend consulting your relevant manuals for appropriate coding options.
The Health Care Provider (HCP) is solely responsible for selecting the site of service and treatment modalities appropriate for the patient based on medically appropriate needs of that patient and the independent medical judgement of the HCP.