Official NTOCC Comments

Review the official comments, letters and responses from the National Transitions of Care Coalition (NTOCC).

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CMS Releases Final FY2013 Physician Fee Schedule; New Transitions of Care Payment

Posted on 11/2/2012 by NTOCC ® in Public Policy Updates

Yesterday, the Centers for Medicare & Medicaid Services (CMS) published a final rule that will update payment rates for services furnished by physicians and non-physician practitioners under the Medicare Physician Fee Schedule for 2013. As you know, NTOCC submitted comments on the proposed rule in September in support of a new payment to primary care physicians to furnish non face-to-face ‚ÄúTransitional Care Management‚ÄĚ services required to help a patient transition back to the community following a discharge from a hospital or nursing facility.

NTOCC strongly supported provisions in the proposed rule to explicitly pay for post-discharge transitional care management services for beneficiaries, and supported the transitional care services defined under CMS’s proposed code as they aligned with NTOCC’s seven essential elements.  The final rule replaces the originally proposed code for physicians and non-physician practitioners coordinating a beneficiary's care with two transitional care management codes developed by AMA's Chronic Care Coordination Workgroup. These two codes split transitional care into “moderately complex” and “highly complex” care and also require a face-to-face visit with the beneficiary within 7-14 days of discharge. However, the modified codes align with CMS’s proposed code and NTOCC’s seven essential elements.
In addition, NTOCC’s comments on the proposed rule pointed out the current challenges facing primary care physicians, and the need to ensure that qualified care transition professionals, including case managers, nurses, pharmacists and social workers, are eligible to provide the proposed transitional care services.  While CMS recognized the importance of these health professionals in furnishing the full range of E/M services and complete medical management of a patient, the final rule states that CMS will “not adopt the requests of other health care professional to bill the CPT TCM codes because these services go beyond the statutory benefit and state scope of practice.”
For more information, please see the CMS fact sheet.  To view the final rule, please click here.