10/05/2016

MSHO at Work for Michigan and the Entire Nation!

MSHO Catches CMS Error

Reviewing this TCM Fact Sheet published by MLN Matters, it appeared that CMS was requiring the physician or advanced practice practitioner to make the "interactive contact" call within 2 days, which is incorrect based on the CMS Final Rule.

After contacting CMS, we received the following update:

We encourage practitioners to follow CPT guidance, and CPT indicates that this call can be made either by the biller or by clinical staff who have “capacity for prompt interactive communication addressing patient status and needs beyond scheduling follow-up care.”

The term “clinical staff” is defined in the same way for TCM as it is everywhere else in the PFS that this term is used. It is a CPT term, and practitioners should consult the CPT definition of the term “clinical staff.” Clinical staff must meet the incident to rules, since they always work incident to, which include things like required supervision and applicable State law. So if there is any applicable state law (which may include licensure and scope of practice), it must be met.

We have requested that the FAQ be corrected and CMS has agreed to make the change in the next publication.