decisionhealth Newsletters, Coder Pink Sheets - 2023 Issue 9 (September)
Rules and regulations: Read the fine print for community health integration services
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Article Overview
This piece reviews the proposed CMS approach to community health integration (CHI) services and explains why practices interested in care management should pay attention to the operational and compliance details. It is aimed at physicians, billing staff, care management teams, and practices evaluating whether the service fits their workflow. The article covers the proposed service structure, the relationship to an initiating E/M visit, incident-to and supervision expectations, limits on concurrent billing, auxiliary personnel requirements, and documentation expectations, along with references to relevant CMS guidance and ICD-10-CM mention for social determinants of health.
Why This Topic Matters
Practices considering CHI services need to understand the proposed requirements before investing time and resources. The article highlights the kinds of operational, staffing, and documentation issues that may affect whether a practice can participate successfully.
Article Sections
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Overview of proposed community health integration services
Introduces the CMS proposal and the general purpose of the new service within care management. Summarizes why the topic may be relevant to practices considering additional service lines.
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An E/M visit comes first
Explains the proposed relationship between CHI services and an initiating evaluation and management encounter. Describes the general categories of visits discussed in the proposal.
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CHI performed incident-to, under general supervision
Covers proposed supervision and staffing arrangements for the service. Discusses the role of auxiliary personnel and the possibility of contracted support through outside entities.
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Certain restrictions apply
Summarizes proposed limits intended to reduce overlap and duplication with other care management activities. Notes the discussion of patient-level and monthly billing limitations.
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Training, state law define auxiliary personnel
Describes how state law and training expectations may affect who can furnish the service. Includes the general categories of competencies CMS identifies for auxiliary personnel.
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Time, services must be documented
Addresses documentation and recordkeeping expectations for time spent and activities performed. Also notes the article’s discussion of coding references related to social determinants of health.
What You Will Learn
- How CMS is structuring the proposed community health integration service
- What type of initiating visit is discussed in the proposal
- How supervision and auxiliary personnel requirements are framed
- What kinds of limits may affect concurrent billing and service overlap
- What documentation and training themes are emphasized for practices
Who Should Read This
- Physicians
- Billing and coding staff
- Care management teams
- Practice administrators
- Compliance staff
Codes Discussed
Code Ranges Discussed
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