A face-to-face visit with the provider must occur within seven to 14 calendar days after discharge. However, if the patient is seen for follow-up of his or her discharge within two business days, then that visit meets the initial contact and face-to-face visit requirements.
Code 99496 should be used if the face-to-face visit requires medical decision making of high complexity within seven days; code 99495 should be used if the face-to-face visit requires medical decision making of moderate to high complexity within seven to 14 days (see the code requirements below). For ease of understanding, think of the complexity as similar to the decision-making complexity component of an E/M office visit code. If the patient has a potentially life- or limb-threatening problem with a significant risk of readmission within the next 30 days and/or if you have to review a large amount of testing and consultation information and yet diagnostic uncertainty persists, high complexity decision making (99496) is likely. In this highly complex scenario, it wouldn’t be safe to make the patient wait more than a week to see you. Otherwise, it is more likely that the situation falls in the moderately complex (99495) realm.
The transitional care management codes require one face-to-face visit, certain non-face-to-face services (as described in the article), and medication reconciliation and management during the 30-day service period.
Code 99495 has the following requirements:
Code 99496 has the following requirements:
Many of the services associated with TCM will occur outside the face-to-face visit. CMS states that clinical staff, under the direction of the physician or nonphysician provider, may provide the following non-face-to-face services:
The physician or non-physician provider must perform the following non-face-to-face services:
The face-to-face visit, then, will involve primarily an examination of the patient, medication reconciliation (if it was not completed previously), and possibly creating orders for follow-up testing, referrals, or other services (such as education programs, community services, rehabilitation services, durable medical equipment, and home health) All of this should be documented.
It is a good idea to make reference to your initial contact note in the face-to-face visit note. These two notes do not have to be combined into one. See below for a recommended paper or electronic template to use in the plan section of your face-to-face visit note.
For use in plan section of visit note.
Medication reconciliation:
[ ] Medication list updated
[ ] New medication list given to patient/family/caregiver
[ ] Referrals made to: _________________________________
Community resources identified for patient/family:
[ ] Home health agency
[ ] Education program: ________________________________
Durable medical equipment ordered:
[ ] DME ordered: ______________________
Additional communication delivered or planned:
Patient education:
Topics discussed: _____________________________________________________
Handouts given: ______________________________________________________
Initial transitional care contact was made on ___/___/___ (see separate note)
Because the TCM codes represent a 30-day service period, they should be billed no sooner than the 30th day after the patient was discharged – not at the conclusion of the face-to-face visit – and the date of service should be the 30th day after discharge. These codes should not be used more than once every 30 days after the initial day of discharge. If a patient returns to see you for the same problem after the initial TCM visit but before the 30 days are up, you can still bill for that visit but will need to use an E/M office visit code such as 99213 or 99214.
Additional E/M services, including preventive services, provided on the same day as the face-to-face TCM visit cannot be billed separately; however, additional E/M services provided after the face-to-face TCM visit can be billed separately. Labs, electrocardiograms, etc., can also be billed separately, even if they occur on the same day as the face-to-face TCM visit. Services such as care plan oversight and anticoagulation management cannot be billed at all during the period covered by the TCM codes. The full list of services that cannot be billed is found in the 2013 CPT guidelines.
Noridian, a CMS contractor for a large part of the western United States (including Arizona where we live) pays approximately $162 for 99495 and $229 for 99496. This compares quite favorably to the reimbursement for established patient office visits 99214 at $105 and 99215 at $141, or new patient office visits 99204 at $163 and 99205 at $202. You’ll want to check the reimbursement rates for these new codes from the Medicare contractor in your area. They should be similar to these numbers. Additionally, many other insurance carriers are now paying for these codes.
While new and established patient visits can be billed using the TCM codes (per the Federal Register and recent CPT changes), payment is the same for both. You may prefer to bill a new patient code (99204 or 99205) in lieu of a TCM code based on the type of exam and information that you need to collect on a new patient. For established patients, you will clearly see an increased benefit to your bottom line when you use the TCM codes rather than the E/M office visit codes.
Specialty designation of the provider has not been specified other than to say that dentists and podiatrists cannot bill these codes. Surgeons who have performed a surgery during the hospitalization typically cannot bill these codes because most surgical follow-up visits are covered under the original surgical payment, which often includes a global period that lasts longer than the 7- to 14- day period during which the face-to-face TCM visit must occur. However, a discharging physician (other than the physician who performed surgery) can use these codes on the 30th day after discharge. Nonphysician providers such as physician assistants and nurse practitioners may also bill these codes following the incident-to coding rules.
A key point to remember is that only one provider, per patient and per discharge, may bill a TCM code during the 30 days following discharge. This creates a potential conflict if the patient follows up with more than one physician post-discharge, a common occurrence. It appears that the first provider to bill will be the one to receive payment.
The toughest problem with these codes is the requirement to contact the patient within two business days of discharge. This is no problem at all if you are the discharging physician, but many family physicians no longer work in the hospital. It is not uncommon for a family physician to be notified of a discharge more than two days after the event or sometimes not at all. So how do you get timely notification? This is a problem that will likely have unique solutions in every setting, but here are a few suggestions:
One of the advantages of contacting the patient before the face-to-face visit is that you and your staff can learn what occurred during the acute care stay and can then proactively obtain relevant discharge summaries, operative reports, imaging reports, tests, labs, and consult notes. This will prevent the dismay of having a patient show up after a hospitalization and you and your staff having no idea what happened to the patient.
If you already have a great way of automatically getting detailed information within a day or two of the patient’s discharge, bravo! You are in a much better situation than most physicians. The traditional way to get details about a patient’s hospital stay has been to contact the hospital records department. That is not always an efficient process. More and more hospitals are offering physician portals where doctors can view and download patient records. If that is available to you, sign up. You should try to get access to the portal of every hospital in your community. Designate one or more staff to log on and download the information you need. If you are lucky enough to be part of a health information exchange in your community, you may need only one log-in versus separate log-ins for each facility.
Once you learn that the patient was discharged, you have precious little time to act. Make sure your office has figured out what should happen after you learn about the discharge. Who will call the patient? Who makes sure additional records are obtained? Who makes the face-to-face visit appointment? We recommend the use of a paper or electronic templates, as described earlier, for managing key steps in the transition of care workflow.
In addition, practices will need to develop a tracking system that reminds them to bill for these services at 30 days post-discharge. Solutions could range from creating a tickler file to creating a new appointment code for TCM and running weekly reports to see which patients have reached the 30-day window.
All of this requires extra work, but most of it is work that you have probably already been doing. Now you can be paid fairly for it, and your patients will benefit. Good luck on your transitions of care!