CMS offers new date of service option for transitional care management

Previously, we described what's changing in the new Medicare Physician Fee Schedule, based on what the Centers for Medicare & Medicaid Services (CMS) published in the final rule on the 2016 fee schedule. Buried in that same rule was a change in how physicians can report the date of service for transitional care management (TCM) services.

Before publication of the final rule, CMS had written that the 30-day period for the TCM service began on the day of discharge and continued for the next 29 days – making the reported date of service the 30th day. However, in the final rule for 2016, CMS wrote:

"Regarding TCM services, we are adopting the commenters’ suggestions that the required date of service reported on the claim be the date of the face-to-face visit, and to allow (but not require) submission of the claim when the face-to-face visit is completed, consistent with current policy governing the reporting of global surgery and other bundles of services under the [physician fee schedule]."

CMS went on to state that it will revise the existing sub-regulatory guidance for TCM services accordingly. CMS provided no timetable for that revision. Most aspects of the final rule are not effective until Jan. 1, so you should probably not adjust your TCM billing practices before then. You should probably also confirm with your Medicare Administrative Contractor that it is prepared to handle TCM claims as described by CMS before submitting such claims.

– Kent Moore, Senior Strategist for Physician Payment for the American Academy of Family Physicians