The Michigan Primary Care
Transformation (MiPCT) Project
PO Webinar July 9, 2014
Part Two – New CMS
Chronic Care Code Update
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CMS Chronic Care Management
Payment Update
• 2015 Physician Fee Schedule released on July 3, 2014 (to be
published in the Federal Register on July 11 but available now on
the CMS website)
• Contains updated language regarding the monthly Medicare
chronic care code (which is posted on the mipctdemo.org website
along with reference material)
• Comment period will extend until September 2, 2014
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CMS Chronic Care Management Payment
Revised – Issued July 3, 2014
Highlights
• Effective Date of Payment and Rate
– January 1, 2015
– $41.92 monthly (expectation of at least 20 minutes of clinical services per
month)
• Which Medicare patients are eligible?
– Beneficiaries with 2+ chronic conditions that:
• Place the patient at significant risk of death, acute
exacerbation/decompensation, or functional decline; and
• For whom care coordination services would be expected to last at least 12
months or until the death of the patient
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CMS Chronic Care Management Payment
Revised – Issued July 3, 2014
Highlights
• Chronic care management definition
– 24/7 access to health care provider in the practice
– Continuity of care with a designated provider
– Systematic assessment of health needs, preventive services, medication
reconciliation
– Creation of a patient-centered care plan document
– Management of care transitions
– Coordination with home/community services
– Secure messaging, internet or other non-face to face communication
available
– Written agreement from beneficiary for CCM services, documented in chart
– Informing beneficiary that only one practitioner can be paid for these
services during the month as well as process for revoking agreement to
participate
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Key Themes
• Focus on “scope of service”, not standards
– PCMH certification standard removed
– NP/PA requirement removed
– EHR 2014 requirement retained (now classified as a scope of service instead of
a standard).
• The person providing CCM services does not need to be a direct employee
of the practice
• CCM services provided do not need to be under the direct supervision of a
physician (general supervision suffices).
• “Clinical staff” (including nurses and clinical social workers) who meet
relevant state requirements (licensing) may deliver care management
services (consistent with MiPCT model)
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Demonstration Extension Update
• Language prohibits “double dipping” from both MAPCP
demonstration and new CMS chronic care code
payment for an eligible beneficiary.
• However, practices could bill the new code for
Medicare patients who are not attributed to the
practice.
• Could be interpreted as a constructive sign of increased
consideration by CMS of demonstration extension,
though CMS has not formally advised the states of
their intent to extend.
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Michigan’s 2013 Submitted Comments
• The new language acknowledges several of Michigan’s comments
to CMS in 2013 and are no longer open issues
– NP/PA Requirement was removed
– Practices do not need NCQA or URAC recognition required
– Patient consent for care management remains in effect until revoked
(annual consent no long applies)
– Requirement that practice employ care management staff has been
broadened
• The following are still items of concern:
– Level of payment is less than ideal
– Payment references non face-to-face care management services only (vs.
also including face to face care management services)
– Patients may bear financial responsibility for care management services
(e.g., deductible, cost sharing, etc.)
– EHR certification level (2014) may be a high bar for some practices
Preparing for 2014 Comment Submission
• Language posted on MiPCT website and distributed to stakeholder
groups upon receipt (ROI subgroup, Operations Group, etc.)
• Comments should be forwarded to dbechel@umich.edu by August
2, 2014 with the subject line: “Comment on CMS Revised CCM
Code Language”
• Discussion opportunities on the new language include:
– The ROI Subgroup meeting (July 14)
– PO Stakeholder Visioning Meeting (July 29)
• Comments will be compiled and reviewed at the August 6
Operations Group meeting and by the Steering Committee to
allow for submission by August 29th
Coordination with Other States
• Discussion has begun with other states
• Opportunity to share consolidated comments
to promote common themes and alternative
language in comments to CMS
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MiPCT Key Messages
Sustainability and Continuity
• Regardless of whether CMS extends the
demonstration period is extended to 2015, MiPCT
discussions with payers have been constructive and
promising overall for continued:
– Care management funding
– Central operations funding for support and accountability
• Final agreements will be announced as soon as
possible
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MiPCT Key Messages
Sustainability and Continuity, cont.
• The MiPCT is a core component of Michigan’s State
Innovation Model (SIM); Further, several POs have already
expressed commitment to ongoing care management
support post demonstration
• We cannot lose focus on using the time left in the
demonstration period to produce continued and improved
results for each payer on:
– Increased volume of MiPCT eligible patients receiving Care Management
– Reduced Avoidable ED and Inpatient Visits
– Improved Clinical Metrics (especially diabetes)
• Your continued and focused efforts now on the key
metrics above are key to success
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