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Thursday, July 16, 2015

Survey shows rise in solo practice physician searches

The number of solo practices looking for new physicians or advanced practitioners rose last year, one of the largest physician recruiters says.

Physician search firm Merritt Hawkins in its annual review says 4 percent of the 3,120 search assignments conducted by itself and affiliated firms between April 1, 2014, and March 31, 2015, were for solo practices. This represents a sizable increase from the year before when solo practice assignments made up less than 1 percent of the company’s workload.

Physician-owned medical groups also made strides, making up 20 percent of search assignments, compared with 13 percent the year before, while those from hospitals fell from 64 percent to 51 percent. But the trend is still clearly with employed practice. Merritt Hawkins said 95 percent of its assignments during the review period were for employed positions, compared with less than half in 2004. Assignments from community health centers and academic positions also increased.

Family physicians continued to be the most frequent search assignment for the ninth year in a row, followed closely by internal medicine, psychiatrists, hospitalists, and nurse practitioners. The firm noted that advanced practitioners, a category combining nurse practitioners and physician assistants, would have been fourth on the list, up from fifth last year. Four years ago, neither made Merritt Hawkins’ top 20 assignments, either together or separately.

“Concierge” and other practice models where patients pay their physician directly for care without going through third-party payers, while gathering increasing attention from physicians, remained a tiny piece of the assignment mosaic. The company said it fielded only 25 assignments for concierge practices during the review period, down from 32 in the previous year.

After hitting a five-year high last year, the average base salary for family physician assignments during the study period fell slightly, declining from $199,000 to $198,000.

While policymakers have increasingly discussed the switch of reimbursement from fee-for-service to models based on quality and value, Merritt Hawkins said only 23 percent of its assignments included bonuses tied to quality metrics, down from 24 percent during the previous year. Fifty-seven percent of assignments still relied on relative value units (RVUs) for measuring physician productivity.

Wednesday, July 15, 2015

CMS opens up 2014 Open Payments data to the public

On June 30, CMS published Open Payments data for 2014 that detail transfers of value, such as direct payments, honoraria, or research grants, by drug and medical device makers to physicians and other health care providers. The data include information about 11.4 million financial transactions, attributed to more than 600,000 physicians and more than 1,100 teaching hospitals, totaling $6.49 billion. The Open Payments program is a product of the Affordable Care Act.  

With this data release, both the 2014 and 2013 financial records are now available to the public. CMS will continue to update the Open Payments website annually to incorporate data collected from the previous year and to include updates to data disputes and other data corrections made since the initial publication. For more information about the program, including how physicians can register so they can review payments tied to them and report potential errors, please visit the Open Payments page on the CMS website.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Thursday, July 9, 2015

CMS considers separate payment for advance care planning

The Centers for Medicare & Medicaid Services (CMS) has released its proposed Medicare Physician Fee Schedule for the 2016 calendar year. Among the many updates is a proposal to pay physicians separately for providing advance care planning to Medicare patients.

Medicare currently pays for such services as part of the “Welcome to Medicare” visit, but patients may not need such services during that first visit. Proponents have said providing a separate payment for advance care planning gives physicians and Medicare patients greater flexibility and the ability to use these services when they are most needed.

CMS is actually proposing two CPT codes: 99497 for the first 30 minutes of advance care planning and 99498 for each additional 30 minutes.

For example, a patient who has been diagnosed and is receiving treatment for heart failure may want to discuss long-term treatment options, such as a heart transplant. The patient may also want to discuss advance care planning in case a health event diminishes his or her decision-making capacity. Under the proposal, the physician in this scenario could report a standard evaluation and management (E/M) code for the E/M service and 99497, as well as 99498 if appropriate. Note, the E/M and advance care planning services would not necessarily have to happen on the same day.

CMS is taking public comments on this and other proposals in the Medicare PFS through Sept. 8. It plans to issue the final rule by Nov. 1.

Tuesday, July 7, 2015

CMS sees smaller approval rate in final ICD-10 acknowledgement test

The Centers for Medicare & Medicaid Services (CMS) says it saw a slight dip in the percentage of accepted claims during its final round of acknowledgement testing ahead of the upcoming ICD-10 change.

During the June 1-5 test, the agency accepted 90 percent of the more than 13,000 test claims it received from 1,238 participants nationally. By comparison, CMS said it accepted almost 92 percent of almost 9,000 test claims during acknowledgement testing in March.

Acknowledgement testing gives physicians and others the opportunity to submit claims with ICD-10 codes to the Medicare Fee-For-Service (FFS) claims systems and receive electronic acknowledgements, confirming that their claims were accepted. CMS did not require volunteers to register, and there was no limit on the number of claims that could be submitted.

CMS officials gave no reason for the slight downturn but did say they didn’t identify any Medicare FFS claims system issues during the test period, as they haven’t in any of the previous acknowledgement tests. They added that most of the rejected claims failed for technical reasons, such as the submitter using an invalid National Provider Identifier (NPI) or the wrong date of service, and not for reasons connected to ICD-10.

Although this was the last special CMS acknowledgement testing week before the ICD-10 code switch on Oct. 1, you are welcome to submit acknowledgement test claims anytime up to the deadline. See MLN Matters Articles MM8858 or SE1501 or contact your Medicare Administrative Contractor for more information.

As a reminder, Medicare claims with a date of service on or after Oct. 1, 2015, will be rejected on and after Oct. 1 if they do not contain a valid ICD-10 code. The Medicare claims processing systems do not have the capability to accept ICD-9 codes for dates of service after Sept. 30 or to accept claims that contain both ICD-9 and ICD-10 codes.

On Monday, the CMS and American Medical Association announced efforts to ease the transition for physicians to the new code set, including a one-year grace period during which CMS will not deny or audit Medicare claims based solely on a diagnosis code being insufficiently specific as long as it is from the appropriate family of ICD-10 codes.

Even though the Oct. 1 implementation date is less than 90 days away, you still have time to prepare for ICD-10, if you have not done so already. CMS has created a number of tools and resources to help you succeed. One tool is the “Road to 10,” aimed at smaller physician practices with primers for clinical documentation, clinical scenarios, and other specialty-specific resources to help you with implementation. The American Academy of Family Physicians also has tools, articles, and other resources available for its members.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Thursday, July 2, 2015

ICD-10 has you covered this Fourth of July

Physician practices will need to switch to ICD-10 coding in about 90 days. It's something to consider as you attend July 4th celebrations this weekend: How would I use ICD-10 to code some frequent holiday-related injuries?

First off, keep hydrated and out of the sun so you don't have to worry about sunstroke (T67.0XXA) or heat exhaustion (T67.5XXA). Also, apply lots of sunscreen to avoid a nasty sunburn (L55.1).

If you are by the swimming pool, careful when you dive. Lots of people get hurt "jumping or diving into swimming pool striking bottom" (W16.52).

Summer weekends are a popular time to pull out the grill (Y93.G2). This is a wealth of potential harm, including burning your fingers (T23.031A) on the open flame (X03.0XXA) or picking up a hot burger by mistake (X10.1XXA). Alternatively, not cooking things correctly can lead to food poisoning (A05.9). Also, watch it with the beer consumption (F10.129, alcohol abuse with intoxication, unspecified).

Lastly, it wouldn't be Independence Day without some fireworks (W39.XXXA). Don't stand so close, and you won't have to worry about getting torched (T20.25XA) or losing your hearing (H93.11). 

Have fun!

Tuesday, June 30, 2015

Place of service matters in Medicare billing

Last December, I reported that the U.S. Department of Health and Human Services Office of Inspector General (OIG) planned to examine place of service (POS) coding by physicians as part of its fiscal year 2015 work plan. Last month, the OIG revealed its findings: Medicare contractors overpaid physicians $33.4 million between January 2010 and September 2012 as a result of incorrect coding related to POS. Specifically, physicians were incorrectly paid for performing these services in non-facility locations, such as physician offices or independent clinics, when they were actually working at facility locations, such as ambulatory surgery centers (ASCs) or hospital outpatient centers.

The difference between a physician’s payment for services performed in the office and services performed in a facility can be significant. Physicians are paid more for professional services performed in their offices than those they perform at hospital outpatient centers and ASCs. When a physician performs in a facility like an ASC, Medicare pays the facility, not the physician, for the facility’s overhead expense. In turn, Medicare pays the physician less under the physician fee schedule because the physician did not have the overhead and much of the other practice expenses of the facility’s location of service.

In the end, it all boils down to the POS reported on the claim. When a physician provides an office-based service, the physician should bill with the correct POS code, generally a POS code 11. When a physician provides a facility-based service, the physician should bill the services with an appropriate POS code reflecting the type of facility, for example, a POS code 22 for hospital outpatient centers or a POS code 24 for ASCs.

So, what can your practice do to avoid such errors? OIG’s report made a number of suggestions, including making sure:

• Billing staff is clear about the definition of “physician’s office” or other non-facility locations and understands the need to code POS appropriately.

• Billing staff is aware that the POS code can affect Medicare payment and that inaccurate use of non-facility POS codes can mean potential Medicare overpayments.

• Billing systems are not designed to submit all physician professional service claims with a non-facility POS code.

• You implement internal controls to identify potential coding errors before claim submission.

As noted, inaccurate use of POS codes can lead to Medicare overpayments, which, in turn, can lead to overpayment recovery efforts on the part of the Centers for Medicare & Medicaid Services (CMS) and its contractors. For instance, based on its findings, OIG recommend that CMS direct its Medicare contractors to initiate, in accordance with CMS policies, the immediate recovery of $7.3 million in potential overpayments from physicians who incorrectly coded physician services performed in ASCs and $19 million in potential overpayments related to the services that may have been performed in hospital outpatient locations. That’s in addition to the $7.1 million in potential overpayments 87 physicians told CMS they intended to pay back for incorrectly coding physician services performed in hospital outpatient locations.

OIG also recommended that CMS and its contractors continue to educate physicians and billing personnel on the importance of internal controls to ensure the correct POS coding for physician services. Finally, OIG recommended stronger and wider efforts to perform coordinated data matches of non-facility-coded physician services and facility claims to identify physician services that are at a high risk for POS miscoding and recover the overpayments that are identified as a result.

All of which means a likely greater focus and scrutiny on POS coding going forward, especially since this is not the OIG’s first inquiry into POS billing.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Friday, June 26, 2015

MACRA changing rules for opting out of Medicare

The Medicare Access and CHIP (Children’s Health Insurance Program) Reauthorization Act of 2015 (MACRA) is simplifying the process that physicians must follow to opt out of Medicare.

Before the law went into effect this spring, the opt-out affidavits that physicians and other providers signed had to be renewed every two years for the opt-out status to continue. Beginning with valid opt-out affidavits signed on or after June 16, 2015, the affidavits will now renew automatically every two years. Physicians who don’t want their affidavit to automatically renew need to notify in writing all Medicare Administrative Contractors (MACs) with which they filed an affidavit. This notification must occur at least 30 days before the start of the next opt-out period.

Affidavits filed before June 16 will expire at the end of two years as before. Physicians wanting to extend the opt out must file to all applicable MACs a renewal affidavit within 30 days after the current opt-out period expires.

For more information on opting out of Medicare, including the effects on contractual obligations and finances, see the article “How to Say Goodbye to Medicare” from the FPM archives.

Friday, June 19, 2015

Study finds no clear winner among Medicare payment models

As Congress considers how to make Medicare spending more efficient and cost-effective, a new study has found it won’t be as easy as picking a single payment model.

The Medicare Payment Advisory Commission, which advises Congress on Medicare, has filed its annual report. Following up on similar research started last year, the group looked at the performance of the three main payment models: fee-for-service (the standard model tied to the provision of tests and procedures), Medicare Advantage (capitated payments per member), and accountable care organizations (groups of physicians and other providers that share in savings and risk).

The commission said it found that no one model performed the best across all 78 markets it studied, with fee-for-service being cheapest in 28 markets, ACOs cheapest in 31 markets, and Medicare Advantage cheapest in 19 markets. Researchers noted there are still few studies comparing the quality and patient satisfaction generated by the three models.

The report said that Medicare may need to change its payment rules to encourage recipients to choose the payment model that is cheapest for their market. For instance, Medicare could set a national base premium for Part-B services that would pay for either fee-for-service/ACOs or Medicare Advantage, whichever was cheaper in a particular market. Or it could calculate premiums at the market level, with higher spending markets having higher premiums, which would again pay for whichever model was cheapest. Note that the researchers folded ACOs in with fee-for-service for this exercise.

The commission also continued to express concerns about how Medicare measures care quality, saying it relied too much on clinical processes that didn’t necessarily lead to better health outcomes and sometimes placed a heavy reporting burden on physicians and other providers. Among the commission's alternatives is a new measure called “healthy days at home,” which measures the number of days during a specific period where a recipient was alive and didn’t interact with the health care system, other than for preventive or maintenance care.

Initial analysis indicates this measure could highlight meaningful differences in health outcomes across populations, especially when applied to patients with one or more chronic conditions. But the researchers also said the measure needed more study to determine if differences in post-acute-care were skewing the results and reflecting differences in practice patterns across geographic areas rather than differences in health status.

Thursday, June 11, 2015

Feds warn about potentially illegal medical director compensation

Federal investigators are warning physicians who serve as medical directors to make sure their compensation agreements aren't violating anti-kickback regulations.

The Department of Health and Human Services' Office of Inspector General (OIG) this week said it recently reached settlements with a dozen physicians across the country who had served as medical directors for various health care organizations. The agency said it determined those physicians' directorship compensation agreements were improper because they were tied to the individual physicians' volume or value of referrals and didn't reflect fair market value of the services they rendered – if they provided any services at all.

In some cases, the physicians also entered agreements that led to an affiliated hospital, health group, or other entity paying the salaries of the physician's office staff. While not paying the physician directly, these arrangements reduced the physicians' actual business expenses, so the inspectors claimed this compensation improper.

The OIG reminded physicians that a compensation arrangement is potentially illegal if any part of it compensates the physician for past or future referrals of federal health care program business. For more information, see "OIG compliance program guidance for individual and small group physician practices" and "A roadmap for new physicians: avoiding Medicare and Medicaid fraud and abuse."

Tuesday, June 9, 2015

New payment model seeks to reduce cardiovascular disease

The Centers for Medicare & Medicaid Services (CMS) is accepting applications from physicians and other health care providers to test a new model for reducing the risk of cardiovascular disease among Medicare beneficiaries.

The Million Hearts Cardiovascular Disease (CVD) Risk Reduction model will pay participating practices to help beneficiaries determine their individual risk for heart attack or stroke over the next 10 years. It will then pay those practices to help high-risk patients identify the best ways to reduce their individual risk factors and encourage them to make those changes, hopefully leading to lower rates of heart attack and stroke in those patients.

CMS plans to operate the Million Hearts CVD Risk Reduction for five years and involve more than 300,000 Medicare beneficiaries and 720 practices. The practices will vary in size and patient case mix and can include physicians in family medicine, general practice, general internal medicine, geriatric medicine, multi-specialty care, or cardiovascular care. Half of the selected practices will actually participate in the model while the other half will serve as control practices.

To be eligible, participating practices must have:

•    At least one provider, which CMS defines as a medical doctor, doctor of osteopathic medicine, physician assistant, or nurse practitioner; 
•    An electronic health record (EHR) system certified by the Office of the National Coordinator for Health Information Technology; and
•    Met the criteria for Stage 1 of Medicare’s meaningful use EHR incentive program.

But how much are you paid? Under the program, each practice chosen to implement the intervention will receive a onetime payment of $10 per Medicare beneficiary in the target population to perform the initial risk stratification. Once the practice has identified the individuals at high risk for CVD, it will receive $10 per beneficiary per month to work with those patients to reduce their risk. CMS may potentially reduce those payments to a practice beyond the first year depending on how well the practice is reducing the beneficiaries' CVD risk. Practices chosen for the control group will receive an annual one-time payment of $20 per Medicare beneficiary in the target population for successfully submitting their data.

If your practice is interested in applying, you must first submit a non-binding letter of intent (LOI) by Sept. 4. CMS will use letters of intent for planning purposes only. Once CMS receives the LOI, practices will have until 11:59 p.m. (EST) Sept. 4 to electronically submit the application. You can access application materials at http://innovation.cms.gov/initiatives/Million-Hearts-CVDRRM/.

For more information on this new payment model, please review the fact sheet and frequently asked questions on the CMS web site.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Thursday, June 4, 2015

Claims acceptance rate rises in latest ICD-10 end-to-end test

With less than four months to go before the transition to ICD-10 coding, the Centers for Medicare & Medicaid Services (CMS) is continuing to make sure the system is ready.

Its latest round of end-to-end testing showed the percentage of failed claims narrowing, most of which it said were caused by technical problems not connected to the new ICD-10 codes.

Between April 27 and May 1, around 875 physicians, other health care providers, and billing companies volunteered to send test claims. Unlike ICD-10 acknowledgement testing, which simply determines if the tester’s claim is accepted or rejected, the end-to-end tests process the claims through all Medicare system edits and provide an Electronic Remittance Advice.

CMS said it accepted 88 percent of the 23,138 test claims submitted, which was an increase from the 81 percent accepted during the end-to-end test conducted earlier this year. It said 2 percent of the claims failed for using an invalid ICD-10 diagnosis or procedure code and less than 1 percent failed for using an ICD-9 code.

Other claims were denied for technical problems, such as using an incorrect National Provider Identifier (NPI), Health Insurance Claim Number, Submitted ID, or HCPCS code, using a date of service outside the valid range for testing, or using an invalid place of service.

CMS said it identified a coding issue involving inpatient hospital claims, which it will fix, and test filers will be allowed to resubmit those claims. An issue with home health claims identified in the January test has been fixed, CMS said.

The final end-to-end testing will be conducted July 20-24.

Tuesday, June 2, 2015

Not all valid vaccine codes are in the book

Vaccine development and subsequent approval by the Food and Drug Administration (FDA) does not always nicely coincide with publication of the Current Procedural Terminology (CPT) manual. Consequently, the American Medical Association (AMA) uses its website to feature updates to the codes for these products, based on actions taken by the CPT Editorial Panel and the FDA.

In general, once approved by the CPT Editorial Panel, AMA makes vaccine CPT codes available for release twice a year, on July 1 and Jan. 1. As part of this electronic distribution, there is a six-month implementation period from the initial release date (i.e., codes released on Jan. 1 are eligible for use on July 1, and codes released on July 1 are eligible for use Jan. 1). In case you missed them, we will discuss some vaccine codes and code changes that do not yet appear in the CPT manual.  

First, the AMA released new codes 90620, for “Meningococcal recombinant protein and outer membrane vesicle vaccine, Serogroup B, 2 dose schedule, for intramuscular use,” and 90621, for “Meningococcal recombinant lipoprotein vaccine, Serogroup B, 2 or 3 dose schedule, for intramuscular use,” on Nov. 1, 2014, for implementation Feb. 1, 2015. Payers may have decided to acknowledge and implement both codes for reporting purposes prior to Feb. 1, but from a CPT perspective, they are now available to use, even though they won’t appear in the CPT manual until 2016. Both vaccines are FDA-approved.

Similarly, the AMA released new code 90697, for “Diphtheria, tetanus toxoids, acellular pertussis vaccine, inactivated poliovirus vaccine, Haemophilus influenza type b PRP-OMP conjugate vaccine, and hepatitis B vaccine (DTaP-IPV-Hib-HepB), for intramuscular use,” on July 1, 2014, for implementation on Jan. 1, 2015. This vaccine is not yet FDA-approved, and the new code will appear in the 2016 CPT manual.

The 2015 CPT manual does include a new code, 90630, for “Influenza virus vaccine, quadrivalent (IIV4), split virus, preservative free, for intradermal use,” and a new code, 90651, for “Human Papillomavirus vaccine types 6, 11, 16, 18, 31, 33, 45, 52, 58, nonavalent (HPV), 3 dose schedule, for intramuscular use.” Both codes are designated in the manual as not yet having FDA approval. However, the product represented by 90630 received FDA approval on Dec. 11, 2014, and the product represented by 90651 received FDA approval on Dec. 10, 2014. The 2016 CPT manual will reflect their FDA approval status.

As a reminder, the codes above only identify the vaccine product. To report the administration of a vaccine/toxoid product, you will need to use an appropriate CPT immunization administration code (e.g., 90460, “Immunization administration through 18 years of age via any route of administration, with counseling by physician or other qualified health care professional; first or only component of each vaccine or toxoid administered”) or an appropriate Healthcare Common Procedure Coding System code, such as G0008, “Administration of influenza virus vaccine.”

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Thursday, May 28, 2015

CMS to change access to PQRS data in July

The Centers for Medicare & Medicaid Services (CMS) is changing how physicians and others access its computer system on July 13, a move that will particularly affect Physician Quality Reporting System (PQRS) participants and their staff.

Specifically, CMS is retiring the Individuals Authorized Access to CMS Computer Services (IACS) system. Current IACS user accounts will transition to another existing CMS system called Enterprise Identity Management (EIDM). The EIDM system allows CMS business partners to access multiple CMS applications.

CMS will move existing PQRS IACS users, their data, and roles to EIDM, all of which will be accessible from the “PQRS Portal” portion of the CMS Enterprise Portal. Users will then access the PQRS Portal to submit data (as needed), retrieve submission reports, view feedback reports, or conduct various administrative and maintenance activities. New PQRS users will need to register for an EIDM account.

CMS has promised more information and resources in the coming weeks. In the meantime, please make sure that your IACS account is active and current and that you’re able to log in. This will help ensure a smoother transition to EIDM. For additional assistance regarding IACS or EIDM, you can contact the QualityNet Help Desk at 1-866-288-8912 (TTY 1-877-715-6222) from 7:00 a.m. to 7:00 p.m. (Central Time) Monday through Friday, or via email at qnetsupport@hcqis.org.  

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians

Thursday, May 21, 2015

July 1 deadline approaching to avoid 2016 Medicare cut

Physicians who did not successfully participate in the Centers for Medicare & Medicaid Services’ (CMS) Electronic Health Record Incentive Program (also known as "meaningful use") in 2014 are scheduled to see their Medicare payments cut in January 2016.

However, those physicians can avoid a cut if they apply for a hardship exception by July 1.

To qualify for a hardship exception, you must show CMS proof that a specific circumstance beyond your control significantly prevented you from complying with the requirements of the program.

You can download instructions and applications (both for individuals and groups) for the hardship exception on CMS’s Electronic Health Record Incentive Programs website.

CMS will review each hardship application and supporting documentation to determine if an exception is warranted.

Newly practicing physicians, hospital-based physicians, and physicians with certain Medicare Provider Enrollment, Chain, and Ownership System (PECOS) specialties (i.e., anesthesiology, pathology, diagnostic radiology, nuclear medicine, and interventional radiology) do not have to apply for a hardship exception. CMS will use Medicare information to determine if these physicians are eligible for an automatic exception.

A hardship exception applies only to the 2016 payment adjustment. You’ll have to submit another, separate application for subsequent years.

Tuesday, May 19, 2015

More answers to questions about chronic care management

The Centers for Medicare & Medicaid Services (CMS) this month released a set of frequently asked questions (FAQs) about the chronic care management (CCM) service for which Medicare began paying this year.

The FAQs reaffirm some of what was already known about CCM and clarify other areas. For instance, regarding date of service and when to submit claims for CCM, answer No. 4 states, in part, “practitioners may bill . . . at the conclusion of the service period or after completion of at least 20 minutes of qualifying services for the service period. When the 20 minute threshold to bill is met, the practitioner may choose that date as the date of service, and need not hold the claim until the end of the month.”

The CMS FAQs also clarify the prohibition on reporting CCM for “facility” patients. For instance, answer No. 6 notes, in part, “CPT code 99490 cannot be billed . . . for services provided to [skilled nursing facility] inpatients or hospital inpatients, because the facility is being paid for extensive care planning and care coordination services.” The answer goes on to say, however, that if the patient is not an inpatient the entire month, time that is spent furnishing CCM services to the patient while he or she is not an inpatient can be counted towards the minimum 20 minutes of service time that is required to bill for that month. Several other questions and answers address when it is acceptable to report CCM under the Medicare hospital outpatient prospective payment system.

Like the CMS fact sheet on CCM, the CMS FAQs emphasize that CCM must be initiated by the billing practitioner during a comprehensive evaluation and management (E/M) visit, annual wellness visit, or initial preventive physical exam (i.e., Welcome to Medicare visit). During an open door forum call for physicians, nurses, and allied health professionals on May 13, CMS staff clarified that, for purposes of CCM, “a comprehensive E/M visit” could be any face-to-face E/M service with a physician, including 99212-99214.

For more information on Medicare’s CCM service, including links to related content in Family Practice Management, check out the related web page on the American Academy of Family Physician’s web site.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family 

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