A pharmacist's supervised deprescribing work can count as billable care management time under the Physician Fee Schedule when it qualifies as an incident-to service. CMS says the applicable supervision and incident-to rules, along with the care management service definition, must be met.
CMS addressed uncertainty about deprescribing
CMS says practitioners had reported uncertainty about whether existing physician care management codes cover deprescribing done between office visits. The agency notes that this uncertainty existed despite clinical consensus that deprescribing is active medical management. Its FAQ addresses the question in the context of supervised medication deprescribing, according to CMS.
The clarification concerns whether qualifying work can count toward reporting a care management service. It does not establish that every medication review or every pharmacist task fits a care management code. Whether a medication should be deprescribed is a clinical decision; patients should discuss medication changes with their own doctor.
Check for separate Part D payment
CMS says medication management is covered under both Medicare Part B and Part D. Deprescribing work already paid for as medication management under Part D cannot also be billed to the Physician Fee Schedule, according to the agency.
For practice owners, the payment history for the work is a separate part of the billing review. A task that fits the care management service definition still cannot be billed to the PFS if that deprescribing work has already been paid for under Part D.
CCM includes ongoing practitioner involvement
For chronic care management, CMS says clinical-staff time codes include ongoing work by the billing practitioner, including oversight, management, collaboration, and reassessment. CMS says this practitioner work cannot be delegated or subcontracted.
A concrete starting point for owners is to identify the care management service the time supports, then check its incident-to and supervision requirements and confirm the billing practitioner's required involvement. CMS's FAQ supports counting qualifying incident-to services as care management time under those conditions.
"These "incident to" services can count as billable time for reporting various care management services to the PFS under the appropriate level of supervision and other applicable "incident to" rules, and consistent with the care management service definitions."
Centers for Medicare & Medicaid Services, FAQs: Billing for Supervised Medication Deprescribing Services Under Care Management Codes on the Medicare Physician Fee Schedule (PFS)
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Frequently asked questions
What prompted CMS to address this billing question?
CMS says practitioners had been unsure whether existing physician care management codes covered deprescribing between office visits. The agency notes that clinical consensus described deprescribing as active medical management.
Can the same deprescribing work be billed to Part D and the Physician Fee Schedule?
No. CMS says deprescribing work already paid for as medication management under Part D cannot also be billed to the Physician Fee Schedule.
Can a pharmacist take over all CCM oversight from the billing practitioner?
CMS says ongoing practitioner oversight, management, collaboration, and reassessment are included in CCM clinical-staff codes. That practitioner work cannot be delegated or subcontracted.
Sources
- FAQs: Billing for Supervised Medication Deprescribing Services Under Care Management Codes on the Medicare Physician Fee Schedule (PFS) (Centers for Medicare & Medicaid Services)
- Frequently Asked Questions about Practitioner Billing for Chronic Care Management Services (Centers for Medicare & Medicaid Services)
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