decisionhealth Newsletters, Part B News - 2023 Issue 9 (September)
Read the fine print to ready for community health integration services
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Article Overview
This piece explains CMS’s proposed community health integration (CHI) service and the practical details practices need to review before deciding whether it fits their workflow. It is aimed at physicians, billing staff, care management teams, and other practice administrators who may participate in or supervise the service. The article covers the proposed service structure, how it relates to an initiating evaluation and management visit, supervision and auxiliary personnel requirements, limits on concurrent billing, and documentation expectations tied to social determinants of health.
Why This Topic Matters
The article matters because it highlights proposed Medicare payment policy changes that could affect care management workflows, staffing arrangements, and month-to-month billing processes. Practices considering CHI need to understand the proposed requirements and restrictions to avoid operational conflicts and compliance problems.
Article Sections
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Overview of the proposed service
Introduces the proposed community health integration service and its relationship to broader care management activities. Summarizes the general structure and the policy context discussed by CMS.
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An E/M visit comes first
Explains the role of the initiating evaluation and management visit and the settings that CMS discusses in connection with that visit. Covers the general relationship between the visit and the start of the CHI billing period.
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CHI performed incident-to, under general supervision
Describes how auxiliary personnel and supervising practitioners are involved in furnishing the proposed service. Addresses proposed supervision and contracting arrangements at a high level.
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Certain restrictions apply
Summarizes proposed limits intended to prevent overlapping or duplicative reporting. Discusses restrictions tied to other care management circumstances and to per-patient monthly billing.
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Training, state law define auxiliary personnel
Covers the role of state scope of practice and training requirements for auxiliary personnel. Includes the general competency areas CMS proposes for personnel in states without applicable laws.
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Time, services must be documented
Addresses documentation expectations for time spent and activities performed in support of the service. Also notes the proposed handling of social determinants of health information in the medical record and claims.
What You Will Learn
- How CMS frames the proposed community health integration service within care management policy
- What kinds of practice roles may be involved in furnishing and supervising the service
- Which operational restrictions and documentation issues practices should review
- How the proposal treats auxiliary personnel training and state scope of practice considerations
- What to watch for in the final Medicare physician fee schedule decision
Who Should Read This
- Physicians
- Billing and coding professionals
- Practice administrators
- Care management staff
- Compliance teams
Codes Discussed
Code Ranges Discussed
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