Transitional Care Management, Part 2: 7 Things Your Practice Might be Doing Wrong

In part one of this series we discussed the motivations behind the creation of the Transitional Care Management (TCM) program, and the three key components that must be furnished in order to bill for TCM services.  In this post, we’re going to discuss some of the common mistakes practices make when implementing their TCM process.

In our years of experience helping groups navigate the TCM guidelines these are the top seven common misunderstandings we see that impact a practice’s ability to put an efficient process into place:

1. The interactive outreach can be completed by a clinical staff member.  It’s not necessary to utilize a provider’s time to complete this requirement.

2. If interactive contact is unsuccessful after two attempts, and the attempts are properly documented, this component of the TCM requirements can still be considered complete.

3. NPPs, including nurse practitioners, physician assistants, and certified nurse midwives, can perform the non-face-to-face services.

4. TCM reimbursement isn’t restricted to the patient’s primary care provider, but only one healthcare provider can bill TCM services in one 30 day period, regardless of timeframe.

5. Even if a face-to-face visit is accomplished within seven days of discharge, the 99496 CPT code can only be utilized for patients with high complexity medical issues.  For moderate complexity, 99495 should always be billed.

6. TCM services can be billed alongside end stage renal disease (ESRD) services.

7. The face-to-face component of TCM can be completed via telehealth. An in-person visit isn’t required if it is deemed to be unnecessary.

Medicare’s Transitional Care Management (TCM) program can be complex to understand, and even more challenging to implement efficiently. Because of this, groups often abandon their attempts to follow its guidance, thus negatively impacting both clinical and financial results.  But, practices who successfully navigate its requirements are able to both benefit financially and also facilitate improved outcomes for their patients. Remember, providing TCM services for just ten patients per month could bring in more than $20,000 in additional annual revenue.

Contact us today for help implementing your TCM process!