Health Center Regulatory Issues

CMS Releases Rule That Improves Care for Health Center Medicare Patients

The Centers for Medicare and Medicaid Services (CMS) released its final rule on the CY2018 Physician Fee Schedule earlier this month.  While this annual rule typically does not impact services for Community Health Centers (because they are not paid on the Physician Fee Schedule), this year’s rule includes some important provisions that boost care for health center Medicare patients.

As we noted in the proposed rule (see NACHC’s comments), through this rule, effective January 1, 2018, health centers and rural health clinics can provide and bill for under Chronic Care Management, Behavioral Health Integration and Collaborative Care Management.

  • Chronic Care Management: Previously health centers could bill for one single Chronic Care Management code, but CMS has extended the codes to allow health centers to bill for more codes and increased the reimbursement to approximately $62 per beneficiary per month. Note that this code cannot be used with any other care management code.
  • Collaborative Care Management: starting January 1, 2018, health centers can provide and be reimbursed for providing care management services to treat patients with behavioral health, psychiatric conditions, including substance use disorder. CMS has not finalized the amount which these services will be reimbursed, but it is expected to be approximately $140 per beneficiary per month. These services must be done in consultation with a psychiatrist and cannot be used with any other care management code.

CMS has created a FAQ document to explain the codes and a comprehensive chart of all of the requirements health centers must meet in order to bill for the services.  NACHC is also preparing trainings on these services, so stay tuned for more information on those trainings.

Also noteworthy is that the rule implements a provision from the 21st Century Cures Act that removes a key stumbling block and allows Medicare eligible health center providers to assign beneficiaries to Accountable Care Organizations. Previously, only health center physicians could assign patients and non-physician providers were required to complete a cumbersome two step assignment process to accomplish the task.  The move will prove helpful in rural areas where the primary care team is often led by a non-physician provider.  Medicare patients at health centers will also likely experience more coordinated and improved quality of care, thanks to the change.  Nearly 10 percent of health center patients rely on Medicare, according to the latest NACHC numbers,  so this is good news all around.