The four types of services in the new recommendations are:
- Anticoagulant management— According to the RUC, payment for this service "would result in a nominal payment ($41 per month for initial 90 days and $14 per month for subsequent 90 days of management." CMS has previously considered these services bundled into the cost of evaluation and management (E&M) for the office visit, and not paid separately.
- Education and training for patient self-management—Levy gave the example of a patient with an established illness or disease, such as diabetes or asthma, who is referred by a physician to a qualified, non-physician health professional for education and training to delay co-morbidities. "These services are clearly separate and distinct from E&M, requiring 30 minutes of education provided by non-physician clinical staff."
- Medical team conference—Levy wrote that when a physician’s involvement in a team conference with the patient and other health professionals may qualify as E&M. "However, if the patient is not present...no separate reporting is allowed by Medicare. Non-physicians, such as dieticians, physical and occupational therapists, are not allowed to separately report the time that they spend in team conferences, whether the patient is present or not."
- Telephone services—If a consultation by telephone ends with a decision to see the patient within 24 hours or next available urgent-visit appointment, the code would not be reported and considered part of the subsequent E&M service, procedure, and visit, or if within seven days of a prior visit, the AMA suggests. The number of these phone calls could be capped, or limited to those just initiated by the patient.
Immediate implementation of the AMA’s recommendations “would signal that CMS is serious about providing incentives for care coordination," Levy's letter says.