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Transitional Care Management

  1. Please clarify responsibility for the TCM interactive contact. Can this be performed by a hospital-employed nurse prior to discharge?

    Answer:
    The provider who is billing the TCM service is responsible for the interactive contact within two days of hospital discharge. This must be performed by the billing provider or clinical staff in the provider’s office, on an incident to basis. The service cannot be performed prior to discharge by a hospital-based clinician. Updated 8/29/2017
     
  2. Please define how TCM visit guidelines apply in this scenario: A post-surgical amputation patient develops a blood clot and the surgeon prescribes anticoagulant therapy. If the primary care provider (PCP) sees the patient for follow up, can this be incorporated into TCM by the PCP? Or is this an inherent risk to the surgery and included in the surgeon’s payment for the surgery?

    Answer:
    If the PCP is billing for TCM, the use of anticoagulant therapy is of important consideration, along with other factors that the PCP will address in managing this patient’s transition post-discharge. Updated 6/9/2017
     
  3. What is the appropriate point in time to bill for TCM?

    Answer:
    The 30-day period for the TCM service begins on the day of discharge and continues for the next 29 days. The date of service you report should be the date of the required face-to-face visit. You may submit the claim once the face-to-face visit is furnished and need not hold the claim until the end of the service period.  Medicare Advantage plans need not follow original Medicare claims processing procedures. Updated 6/9/2017
     
  4. May a visit for TCM be performed and billed on the same date of service as an AWV?

    Answer:
    The TCM appointment may take place on the same date as the AWV. It is important to note that all expected elements of both services must be documented in the medical record individually. Updated 6/9/2017

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