Keep track of your CCM work — your own and your vendor’s — to avoid trouble

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Note:  The following article synopsis was NOT provided by HCPro. It was created by Find-A-Code/innoviHealth.

Article Overview

This article explains why chronic care management (CCM) arrangements can create compliance risk when practices rely on vendors to help with service administration. It discusses a Department of Justice settlement, CMS guidance on who must perform CCM work, and practical concerns about tracking and documenting monthly service activity. The piece is aimed at practices, billing professionals, and compliance staff who manage CCM programs and vendor relationships.

Why This Topic Matters

CCM programs are a common source of audit and billing risk because the service is spread across clinical and administrative tasks and may involve outside vendors. Understanding the boundaries of delegated work, documentation, and monthly tracking helps practices reduce exposure to compliance problems.

Article Sections

  1. DOJ settlement and CCM vendor compliance concerns

    Summarizes a government enforcement action involving CCM-related services and highlights the broader compliance concerns that can arise when vendors are part of the workflow.

  2. CMS guidance on billing practitioner responsibility

    Discusses CMS commentary on CCM billing responsibilities, including the role of the billing practitioner and the limits of delegation. It also notes the article’s reference to related service categories and care-team participation.

  3. Tracking monthly CCM activity and patient monitoring

    Explains the importance of ongoing patient tracking, documentation, and care coordination in monthly CCM operations. The section emphasizes monitoring responsibilities and recording service time.

  4. Resources

    Lists external references cited in the article, including government and CMS source materials.

What You Will Learn

  • How CCM vendor arrangements can create compliance risk
  • What general responsibilities remain with the billing provider
  • Why monthly tracking and documentation matter in CCM programs
  • Which types of source guidance the article cites

Who Should Read This

  • Physician practices
  • Billing and coding professionals
  • Compliance officers
  • Revenue cycle staff
  • Care coordination teams

Codes Discussed


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