NARHC Forum

Contributor: Jackie King, ArchProCoding

Good afternoon, 

I could use some feedback from you all on whether or not you are billing for both CCM (G5051) and TCM in the same month successfully.

I have read many publications that are steering me away from billing both a G5051 and a TCM code in the same calendar month at an RHC.  I have also gotten feedback from an outside consultant that this is allowable, however I am concerned that the consultant is quoting PFS rules and is not as familiar with RHC rules. 

The HCPCS ll code description for G5051 is: Rural health clinic or federally qualified health center (RHC or FQHC) only,
general care management, 20 minutes or more of clinical staff time for chronic
care management services or behavioral health integration services directed by
an RHC or FQHC practitioner (physician, np, pa, or cnm), per calendar month.  

When I see "per calendar month" it makes me feel that the MAC is going to be watching for other charges in that calendar month and denying those that are not allowed to be billed with the G5051.  

The Rural Health Information Hub at ruralhealthinfo.org states the following:

 

Are there any special considerations for Rural Health Clinic (RHC) and Federally Qualified Health Center (FQHC) billing for TCM?

RHCs and FQHCs can bill for the face-to-face visit component of TCM as an RHC or FQHC visit. TCM services can be billed as a visit if it is the only medical service provided on that day with a RHC or FQHC practitioner and it meets the TCM billing requirements. If TCM is furnished on the same day as another visit, only one visit can be billed.

 RHCs and FQHCs may not bill for CCM and TCM services, or another program that provides additional payment for care management services (outside of the RHC AIR or FQHC PPS payment), for the same beneficiary during the same time period. 

My question is, does this mean that the TCM can be billed with the CCM as long as the dates don't overlap?  EXAMPLE: A patient is discharged from Inpatient on July 27 and is seen for a TCM visit on August 3.  Then the patient is enrolled in CCM at an August 28 visit and between that visit and the following Monday, August 31, 20 minutes are reached which would enable a G5051 to be billed. Will this deny or be allowed?

 

 I appreciate any assistance you can provide to clear this up,

Jackie King @ ICAHN

jking@icahn.org

 

 

 

 

 

.

Top

Contributor: Nathan Baugh, National Association of Rural Health Clinics

Jackie,

This is a tricky one. I don't know if there is anything from the government that explicitly addresses this scenario. 

My sense is that if the TCM service, straddled two months, such as in your example then you wouldn't be able to provide and bill for a CCM service until the next month (September in your example). Not sure if the MACs have a different interpretation, and I would be interested to hear if anyone has direct experience with this.

Top