Payment Matters: CMS Proposes Additional Payments for Care Coordination by Primary Care Physicians

When CMS published its Proposed Physician Fee Schedule [PDF] rules in the July 30, 2012 Federal Register, it included the creation of new codes to allow payment to primary care physicians and non-physician practitioners for post-discharge care management services. CMS emphasizes in the preamble to the Proposed Rule that primary care and care coordination are crucial to the Medicare program goals. The proposal recognizes that, while non-face-to-face management services have in the past been bundled into evaluation and management codes (E/M codes) and not paid for separately, the E/M codes may not adequately reflect all of the resources and services necessary to provide coordinated care management upon discharge from facilities such as hospitals or skilled nursing facilities. Comments on the proposed rule are due by September 4, 2012.

Specifically, the Proposed Rule addresses this deficiency by creating a new Gcode that can be billed by primary care physicians who coordinate services for a beneficiary after discharge from a hospital, in order to capture the activities involved in the patient's transition from the treating physician in the facility to a "community physician and NPP." CMS anticipates that most community physicians and NPPs will be primary care physicians. The code would be paid for all non faceto- face services provided by the community physician or qualified non-physician practitioner (NPP), or by clinical staff or office-based case mangers under the supervision of the physician or NPP, provided within 30 days of discharge. The new code would be payable once during the transition period to a single community physician or NPP who assumes the responsibility for the patient's post discharge transitional care management. In order to pay only once, CMS will accept the first claim it receives....