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Non-Face-to-Face Revenue Opportunities and Pitfalls

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Presentation on theme: "Non-Face-to-Face Revenue Opportunities and Pitfalls"— Presentation transcript:

1 Non-Face-to-Face Revenue Opportunities and Pitfalls
Moderator: Steven Phillips, MD Panelists: Stephen Canon, MD Gary Swartz, JD MPA

2 Faculty Disclosures Canon – Phyzit, Inc – Co-Founder, Chief Medical Officer Phillips – FEMR Group – Founding member Swartz – no relevant disclosures

3 Objectives Differentiate between the different non-face-to- face revenue opportunities. Discuss the pitfalls related to the opportunities.

4 TRANSITIONAL CARE MANAGEMENT
Stephen Canon, MD Program Director & Associate Professor UAMS Department of Urology Chief, Division of Pediatric Urology ACH Auxiliary-John F. Redman, M.D. Endowed Chair Arkansas Children's Hospital Chief Medical Officer, Phyzit®, Inc.

5 Outline Review the impact of hospital readmission and the impact of Transitional Care Management (TCM) Discuss the “5 Biggest Mistakes of Transitional Care Management” Review the 2016 CMS TCM Fee Schedule Changes Discuss the interface between TCM and Chronic Care Management

6 Hospital Readmissions
For every 5 Medicare patients admitted to the hospital, how many will be readmitted within 30 days after discharge? Almost 1 of 5 patients are readmitted per month In 2011, 1.8 million 30 day Medicare readmissions – cost $24 billion

7 What conditions have the highest readmission rates (2011)?
Congestive Heart Failure Septicemia Pneumonia COPD Cardiac dysrhythmias 134,500 92,900 88,880 77,900 69,400 June 10, 2013

8 Transitional Care Management
The Centers for Medicare and Medicaid Services (CMS) added transitional care management (CPT Code 99495/99496) to the list of services that are reimbursable in January, 2013. CMS invested an estimated 1.34 Billion dollars per year through creation of TCM codes Does TCM really lower readmissions?

9 Systematic review of 3 databases between 2004-2015 that report on readmissions in the US
Of 969 studies identified - 77 met inclusion criteria but only 3 included all elements for TCM

10 Readmission reduction 8.87 % 1.8 % 19.9 %

11 Transitional Care Management Services Requirements
Initial Communication within 2 business days Face-to-face visit in 7 (high complexity) or 14 (mod complexity) calendar days Date of Service (DOS) on 30th calendar day with day 1 being the date of discharge (Jan – Dec 2015)

12 TCM Timeline

13 5 Biggest Mistakes of TCM
Failure to make initial communication with patients fast enough Failure to understand the metrics Failure to correctly identify TCM candidates Failure to schedule face to face in the right time frame Billing the wrong date of service (before 1/1/16)

14 CMS 2016 TCM PFS Changes The DOS will reflect the date of the face-to- face visit: High Complexity – within 7 business days Moderate Complexity – within 14 business days

15 CMS 2016 TCM PFS Changes The service period has not changed with only one billable TCM per service period, AND Only TCM or CCM are typically billed during the same calendar month.

16 Anticipated Effect of Mistake #5
Problems with billing occurring with: Other Admissions/TCM periods Chronic Care Management Awareness of completion of the TCM period is imperative in both scenarios.

17 TCM/CCM Interface Medicare and CPT specify that CCM and TCM cannot be billed during the same month. Does this mean that if the 30-day TCM service period ends during a given calendar month and 20 minutes of qualifying CCM services are subsequently provided on the remaining days of that calendar month, CPT code cannot be billed that month to the PFS?

18 Future of TCM Improvement in awareness of hospital admission/discharge
Workflow integration with electronic medical records and chronic care management Maintaining value for PCPs in the future for continuation of TCM

19 Care Management Services use for Practice Transformation and payment under Value Based Payment Models Gary H. Swartz, JD, MPA Associate Executive Director American Academy of Home Care Medicine

20 Care Management Services Support DHHS Announced Goal of Transformation to Quality and Alternative Payment Models Many of you saw this in presentation this morning with Dr. Smith with phases CMS going to 90% by 2018

21 Care Management Services - Why
Spring rulemaking and fall final to begin the program in 2019 lets look at top line where from this year to there is to be .05 increase to fee schedule

22 How much can payment be reduced unless excluded from Merit Based Incentive Payment (MIPs) System?
Year Potential reduction 2019 based on 2018 minus 4 percent 2020 based on 2019 minus 5 percent 2021 based on 2030 minus 7 percent 2022 and after minus 9 percent can go down up to 9% off of MFS so this in important Sliiding scale against threshold So consider what receiving less than Medicare Fee Schedule would mean budget neutrality except if all do poorly or all do exceptional well The Government Accountability Office (GAO) is required to evaluate the MIPS and issue a report in and 2021, including an assessment of the professional types, practice sizes, practice geography, and patient mix that are receiving MIPS payment increases and reductions.

23 MIPS +/- 9% adjustment in 2019 forward applied to illustrative housecall codes
Description 2016 MD -9% +9% 2016 NP/PA 99327 Domicil/r- home visit new pat $ $ $ $ $ $ 99336 home visit est pat $ $ $ $ $ $ 99344 Home visit new patient $ $ $ $ $ $ 99349 est patient $ $ $ $ $ $ G0181 Home health care supervision $ $ $ $ $ $ 99490 Chron care mgmt srvc 20 minutes $ $ $ $ $ $ 99497 Advncd care plan 30 minutes $ $ $ $ $ $ Why we are working to protect your services in light of the plus minus 9% and current value based payment modifier we know due to the interaction of laws that the MFS will be within a couple of percent of this yeaar even if in full.5 percent so using this year – this is to be budget neutral so for those below there will be those above and vice versus. Standalone compliance on medical necessity – OIG is looking at the medical justifcation for home visits So make sure that discussion in the CC/HPI is there in the record why you are seeing the patient in the home in liew of office vist

24 Care management services - current
Counseling and Care Coordination Prolonged Services Care Plan Oversight - CPO Transitional Care Management - TCM Chronic Care Management - CCM Advanced Care Planning - ACP

25 Care management services under development
Chronic Care Management Revisions – additional codes with more precision for more extensive non face to face services per month Acute Non Face to Face Care Management Services - 30 minutes or more per month of physician or other qualified health professional time, per episode of acute illness Atypical complexity - Atypically complex communication factors or extensive additional evaluation related to medical, behavioral, functional or social factors or atypical care coordination on the date of the E/M Assessment & Care Planning for Patients with Cognitive Impairment - Comprehensive assessment of and care planning for the patient with cognitive impairment Behavorial Health Collaborative Care/Psychiatric Collaborative Care - care manager time (70, 60) with consultation by a psychiatric physician or other qualified health care professional, directed by the treating physician or other qualified professional

26 Care management services and practice transformation
Common elements of care management services Transformed practice functions; Proactively manage across sites of care 24/7 access to practice Electronic health record Maintain an electronic care plan Ensure beneficiary access to care Facilitate transitions of care and referrals; medication reconciliation each transition Coordinate care with home and community-based clinical service providers Obtain patient preferences and goals of care Staffing/relationships for 24/7 access Patient stratification and interventions Open scheduling for acute issues that arise Real time EHR relationship with inpatient facilities Access Regional health information organizations Proactive contact with patients, caregivers, ALFs; use of internal staff or contractual Chaperone patients through admissions Liaison with hospitalists and discharge planning Liaise with SNF staff/see patients in SNF Substitute practice services for those of more costly providers/suppliers, e.g., home health Communicate/respect patient preferences and goals of care Required Elements for Success Across Each Setting   Patient management in the home proactive leadership and culture practice capacities: human, financial, and organizational capital; adaptability and practice flexibility (ie, freedom of decision making) functional ability to deploy the above capacities (people, technology, roles) to ensure situational awareness and ability to intervene in a setting of care and across settings of care professional/clinical and administrative skills: the right training, skill sets, confidence, and demeanor to succeed in relation to the home-limited, sick, frail or disabled patient population

27 Comprehensive Primary Care + (CPC+) Begins 2017
25 million patient, multi-payer 5 year demonstration Opportunity for Academy members to receive per patient per month payment in addition to Part B payments to support care management and practice transformation CMS designation as Advanced Alternative Payment Model Multi-payer aspects provide opportunity to embed HBPC Two tracks – Risk adjusted (HCC) care management capitation paid to practices New CMMI Demonstration Not a proposed rule for comment

28 The CPC+ Care Management Functions
systematically risk stratify patient population, identify high-risk patients likely to benefit from longitudinal care identify event triggers - hospitalization, ED visit, new diagnosis for episodic care Access and Continuity ensure 24/7 access to care team with real-time access to EMR empanel patients to a practitioner/care team to build a therapeutic relationship Planned Care for Population Health team-based care, proactive evidence-based management of chronic conditions act on the quality of care at both the practice and panel level Patient and Family Caregiver Engagement engage patients and families in the design and improvement of care engage patients in goal setting and shared decision-making Comprehensiveness and Coordination provide comprehensive primary care services. understand where in the medical neighborhood patients receive care and organize the practice to facilitate coordination of that care Many practices already have medical neighborhood relationships And staff that are paid by CCM Track 1 practices will build capabilities in behavioral health, self-management support, and medication management to better meet the needs of these patients. Track 2 practices will provide more intensive care management for their patients with complex needs and will build additional practice capabilities in assessment and management of patients with complex needs, such as those with cognitive impairment, frailty, or multiple chronic conditions. Track 2 practices will be expected to explore alternative means of access to reduce barriers to timely care, such as e-visits, phone visits, group visits, home visits, and visits in alternate locations (e.g., senior centers and assisted living centers). Track 2 practices may also more directly involve patients and families in quality improvement initiatives, and must provide self-management support as well as support for caregivers of persons with functional disabilities (e.g., dementia).

29 Medical Home Model is an APM that has the following features:
Primary care or multispecialty practices with primary care Empanelment of each patient to a primary clinician; and At least four of the following: Planned coordination of chronic and preventive care. Patient access and continuity of care. Risk-stratified care management. Coordination of care across the medical neighborhood. Patient and caregiver engagement. Shared decision-making. Payment arrangements in addition to, or substituting for, fee-for­-service payments.

30 Care management services for your home care medicine practice FFS payment and other benefits
MD/DO NP/PA Other benefits Counseling and Coordination of Care Code selection Care management fees Capitation Shared saving Foundation for alternative payment models Measure satisfaction Re24/7 access EHR Patient tracking and management across settings of care Medication reconciliation Reduced admissions Reduced readmissions Patient preferences Patient/caregiver satisfaction Prolonged Services $ $ Prolonged Services $ $ Home Health Care Plan Oversight – G0181 $ $ Hospice Care Plan Oversight – G0182 $ $ Transitional Care Management – 99495 $ $ Transitional Care Management – 99496 $ $ Chronic Care Management $ $ Advanced Care Planning – 99497 $ $ Advanced Care Planning – 99498 $ $ Note services under review and new faqs

31 Comprehensive Primary Care+ PBPM compared with IAH Year 1 Results and Private Market Examples
CPC+ Track 1 Average Track 2 CPC+ Track 2 Complex Tier IAH Year 1 Blended Shared Savings (if PBPM) Northwest US Example Texas $15 $28 $100 $396 $ $ Plus Fee for Service Plus Shared Savings So the private market is reconizing the benefits of hbpc and the Practices are doubling revenue based on care management payments Important to sustain practice particularly community based And to be able to recruit and retain medical professionals

32 Example of value of shared savings
Number of shared savings patients/ provider 25 50 75 IAH year one savings per beneficiary $3,000 Total savings to practice – Approx. 50 percent after application of performance measures $75,000 $150,000 $225,000 50-60 IAH patients is the modeOne million dollars to 4 person group shared savings story by Patrick Conway, MD, Medicare Deputy Director and Director of Innovation Center

33 CHRONIC CARE MANAGEMENT
Steven L. Phillips, MD Medical Director Sanford Center for Aging Professor of Clinical Internal Medicine University of Nevada School of Medicine

34 One of the greatest challenges facing elders is the increase in the number of chronic conditions as they age. Chronic conditions can stem from a range of causes and often impact an individual’s quality of life and experiences.

35 Chronic Conditions and Impact on Health Care
133 million Americans suffer from at least one chronic condition 70% of all deaths result from chronic diseases 85% of all healthcare dollars go to treating chronic disease Two-thirds or more of Medicare dollars spent on patient with five or more chronic diseases

36 63% of patients with six or more chronic conditions were hospitalized one or more times, compared to 4% of those with 0 or 1 chronic conditions 49% of patients with six or more chronic conditions received post-acute care, compared to less than 1% of beneficiaries with 0 or 1 chronic conditions 70% of patients with six or more chronic conditions had one or more Emergency Department (ED) visits, compared to 14% with 0 or 1 chronic conditions

37 Disproportionate Share of Hospital Readmissions
6 or more Chronic Conditions percent 4 to 5 Chronic Conditions percent 2 to 3 Chronic Conditions percent 0 to 1 Chronic Conditions percent

38 The Centers for Medicare and Medicaid Services (CMS) added chronic care management (CPT Code 99490) to the list of services that are reimbursable.

39 Chronic Care Management Services
20 minutes of non-face-to-face care per calendar month Two or more chronic conditions expected to last at least 12 months. Patient at significant risk of death, acute exacerbation or functional decline Comprehensive care plan established, implemented, revised or monitored

40 Eligible Chronic Conditions
Acquired Hypothyroidism Acute Myocardial Infarction Alzheimer’s and other dementia Asthma Diabetes Mellitus Anemia Benign Prostatic Hyperplasia Colorectal, Breast, Lung, Prostate Cancer Cataracts

41 Eligible Chronic Conditions
Chronic Kidney Disease Hypertension Chronic Obstructive Pulmonary Disease Heart Failure Hip/Pelvic Fracture Depression Glaucoma Hyperlipidemia

42 Requirements to Participate
Secure the eligible beneficiary’s written consent Provide five specified capabilities Provide 20+ minutes of non-face-to- face services per calendar month

43 Five Specified Capabilities
Use a certified Electronic Health Record Maintain an electronic care plan Ensure beneficiary access to care Facilitate transitions of care and referrals as needed Coordinate care with home and community- based clinical service providers

44 Practitioners Eligible to Bill Medicare for CCM
Physicians Advanced Practitioner of Nursing Physician Assistants Clinical Nurse Specialist

45 Non-Face-to-Face Care Management Team
Physicians Clinical Nurse Specialist Advanced Practitioner of Nursing Licensed Practical Nurse Registered Nurse Certified Medical Assistant Certified Nursing Assistant Licensed Clinical Social Worker Physician Assistant

46 Chronic Care Management in the Post-Acute Long Term Care Continuum
Data Management Key to: - Patient Identification - Care Coordination Risk Stratification: - Analysis of patients’ health history - Calculation of Hierarchical Condition Category (HCC)

47 Care Coordination Care Plan Development - Cloud-based technology - Integrates data from EMR - Automatically populates a care plan - Action plan based on chronic conditions

48 Care Plan Distribution
Electronic platform shares care plan - Patient - Family - Caregiver - Specialists - Other involved providers

49 Panel Discussion Go to: 2Shoesapp.com/AAHCM2016
Click on the session you are in Ask and vote on questions


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