In the May 20, 2019, issue of Part B News we look at the parts of chronic care managment (CCM) services providers can and cannot outsources to vendors -- and how one CCM vendor got in trouble for providing services improperly. Linda King, client success specialist at DocsInk in Wrightsville Beach, N.C., which offers a platform for clinicians, pharmacists and vendors to manage CCM services, gives us her checklist of questions you should run by any vendor you're considering to provide these services for your CCM program.
1) Question the CCM services company as to their knowledge of CMS regulations for participation, clinical services, documentation and billing. Make sure the services company is dedicated to compliance and committed to improving health outcomes, rather than just for the revenue generation potential. Recommended questions should include (but are not limited to):
- Will the practice/provider/care team have immediate access to all documentation for a patient? (Documentation should always include the patient's "opt-in" and "opt-out" dates along with documentation of the patient's verbal consent to enroll in CCM and their understanding of the program and associated costs.)
- Does the CCM services company provide a complete documentation and audit trail to substantiate time spent and services performed per patient?
- Does the CCM services company have an electronic patient-centered care plan to utilize for CCM services, which meets all of CMS requirements? How and when is this care plan shared with the patient and the care team?
- Because all complex CCM services must involve the billable provider directly performing moderate or high-level MDM during the service period, what does that collaborative process look like and how is it documented?
- How does the CCM services company provide the required 24/7/365 access to the CCM patient population?
- What on-demand reporting is available, at both the patient and organization level, to be shared with the provider/practice?
2) Make sure that the "clinical staff" members used by the CCM services company meet your specific state law and licensure requirements for scope of practice.
3) Request, review, approve and execute the CCM services company's Business Associates Agreement under HIPAA.
4) Check references before contracting with such a company, and continually ask patients for feedback about the program. We have found that when a CCM program is successfully implemented, patients appreciate the extra "touches" between scheduled visits and they experience a high level of overall satisfaction.