Frequently Asked Questions

Do You Have Questions About Transition of Care Management?

Learn more about the revenue opportunites, requirements, and benefits of transition of care management (TCM) services below.

Who is eligible to provide TCM services?

Physicians of any specialty and non-physician practitioners (NPPs) including:

• Certified nurse-midwives (CNMs)

• Clinical nurse specialists (CNSs)

• Nurse practitioners (NPs)

• Physician assistants (Pas)

What services do eligible physicians and non-physician practitioners provide?

• Obtain and review discharge documents (for example, the discharge summary or continuity of care documents)

• Review need for a follow-up on pending diagnostic tests or treatments and assist in scheduling the required follow-up with healthcare and community services providers

• Interact with other health care professionals who will assume or reassume care of the patients’ specific needs

• Provide education to the patient, family, guardian, and/or caregiver

• Establish or re-establish referrals and arrange for necessary community services

Can practitioners use individuals outside of their practice to provide services?

Yes, providers may use licensed clinical staff outside of their practice to provide TCM services subject to the Medicare “incident to” rules and all other applicable Medicare rules. For payment of TCM services under the Physician Fee Schedule, CMS requires direct supervision for the face-to-face visit, but all other TCM services may be provided under general supervision.

Under the supervision of a physician or non-physician practitioner, what services may clinical staff provide?

• Identify available care resources and communicate with the agencies and community services the patient will use

• Assist the patient and/or family in accessing necessary care and services

• Provide education to the patient, family, guardian, and/or caretaker

• Assess and support treatment regimen adherence and medication management

Who may receive TCM services?

Beneficiaries discharged from:

• Inpatient Acute Care Hospitals

• Inpatient Psychiatric Hospitals

• Inpatient Rehabilitation Facilities

• Hospital outpatient observation or partial hospitalization

• Long-Term Care Hospitals

• Skilled Nursing Facilities

• Partial hospitalization programs at a Community Mental Health Center

What are the TCM program requirements?

• Care coordination for the 30 days following patient discharge from hospital

• Patient contact within two business days of discharge (can be non-face to face)

• Creation of a care plan that can be shared electronically with patient and other providers

• Other non-face-to-face services (review discharge instructions, medicine reconciliation, care coordination with other providers and community services, patient/caregiver communication and education)

• Follow up appointment/face to face visit within 7 days (high medical decision complexity) or 14 days (moderate medical complexity) of discharge

Is the face-to-face visit required to be in the office?

No, CMS has established both a facility and non-facility MPFS payment for this service. Practitioners should report TCM services with the place of service appropriate for the face-to-face visit.

What are the initial patient contact requirements?

• Initial contact within two business days of discharge - may be by direct contact, telephone, or electronic means

• Must include capacity for prompt interactive communication addressing patient status and needs beyond scheduling follow-up care

• May be performed by clinical staff under the general supervision of a qualified professional

• Date of communication (or two failed attempts) must be documented

What constitutes medical decision making of moderate or high complexity?

• Moderate complexity: multiple possible diagnoses and/or management of options; moderate complexity of medical data (e.g., tests) to be reviewed; and moderate risk of significant complications, morbidity, and/or mortality, as well as co-morbidities.

• High complexity: extensive number of possible diagnoses and/or management of options; extensive complexity of medical data (e.g., tests) to be reviewed; and high risk of significant complications, morbidity, and/or mortality, as well as co-morbidities.

What is the reimbursement for TCM services?

Average reimbursement ranges from $165 (14-day follow up visit) to $233 (7-day follow up visit) per 30 day episode.

What date of service should be used on the claim?

The date of service you report should be the date of the required face-to-face visit. You may submit the claim once the face-to-face visit is completed and need not hold the claim until the end of the service period.

Which CPT codes are used to report TCM?

There are two CPT codes for TCM. The code you will bill will depend on the timing of the face-to-face visit and the degree of medical complexity:

•CPT Code 99495 – Transitional care management services with moderate medical decision complexity that requires a face-to-face visit within 14 days of discharge.

•CPT Code 99496 – Transitional care management services with high medical decision complexity requiring a face-to-face visit within 7 days of discharge.

If the patient is readmitted in the 30-day period, can TCM still be reported?

Yes, TCM services can still be reported as long as the services described by the code are provided by the practitioner during the 30-day period. Alternatively, the practitioner can bill for TCM services following the second discharge for a full 30-day period as long as no other provider bills the service for the first discharge.

If more than one physician reports TCM services for the same patient during the 30 days post-discharge, how will Medicare determine whom to pay?

TCM services can only be billed by one individual during the 30-day period after discharge. If more than one physician or NPP submits a claim for TCM services provided to a patient in a given 30-day period following discharge, Medicare will pay the first claim that it receives that otherwise meets its coverage requirements.

During the 30 day period of TCM, can other medically necessary billable services be reported? What about chronic care management services?

Other reasonable and necessary Medicare services may be reported during the 30 day period, with the exception of those services that cannot be reported according to CPT guidance and Medicare HCPCS codes G0181 and G0182. CCM could be billed during the same calendar month as TCM only if the TCM service period ends before the end of a given calendar month, and at least 20 minutes of qualifying CCM services are subsequently provided during that month, and all other CCM billing requirements are met. However, the majority of the time, CCM and TCM will not be billed during the same calendar month.

How does AviTracks-TC software help with TCM?

AviTracks-TC helps to automate the management of patients in care transitions to improve outcomes and reduce hospital readmissions. With AviTracks-TC you can automate and customize your workflow, optimize your staff’s efficiency and maximize your TCM reimbursements.

What are the key features of AviTracks-TC?

• Enables team-based care and care coordination across providers

• Creates electronic care plans, assigns teams and separates the tasks among physicians, nurses and coach coordinators

• Creates custom questionnaires for patient follow up

• Records and logs time for every interaction with the patient

• Assigns a risk level to each patient and adjusts tracking based on the risk profile

• Flags patients by condition, risk or program for easy identification and monitoring

• Can be implemented across multiple care provider teams, letting each group focus on their work while sharing critical information

• Reports statistics by user so that administrators may view staff workload as well as identify highly efficient nurses, coaches and care coordinators

• Creates documentation for billing purposes including CMS CPT codes 99495 and 99496

Is there specific technology required to install AviTracks-TC software?

No, because AviTracks-TC is a cloud-based web application, no new software or hardware is required.

What type of security does AviTracks-TC offer? Is it HIPAA compliant?

AviTracks-TC is hosted on a nationally recognized cloud provider with five fully redundant data centers in the geographically safe Midwest region. Our IT infrastructure is audited annually for HIPAA, PCI, SSAE-16, SOC 1, SOC 2, and Safe Harbor compliance to ensure the safety of our software and patient data. Encrypted technology protects patient data both in transit and at rest.

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