Ask the Expert

This month’s selection:
My organization has a hospitalist group that will be overseeing a new protocol for discharging COPD patients that is interested in reporting transitional care management codes. A patient is discharged from an inpatient stay, still with moderate to high-complexity issues. Within two days, a pharmacist calls the patient for medication reconciliation. Within the required time period, a nurse practitioner conducts a face-to-face visit either at the patient’s home or the physician’s office.

All of the requirements for transitional care management will be performed and documented, however, I am concerned about the pharmacist. Does the pharmacist need to be employed by the physician group or should there, at minimum, be some sort of financial agreement regarding the pharmacist’s services? Additionally, I would think the services must be reported by the nurse practitioner, as this could not be an incident to service. Any advice?

Cristy Donaldson, CPC, CPMA
Coding Specialist
University Physicians’ Association, Inc

 

Response:
To report the transitional care codes, the clinical staff needs to be directed by the provider. The CMS Physician Final Rule states, "In response to the comment on appropriate clinical staff type for non–face-to-face care management services, we note that we are accepting the AMA RUC recommended clinical labor staff type of an RN/LPN for conducting non–face-to-face care coordination activities." This can be found at www.gpo.gov/fdsys/pkg/FR-2012-11-16/pdf/2012-26900.pdf. The scenario you describe would not meet the requirements to report transitional care management.

— Raemarie Jimenez, CPC, CPMA, CPC-I, CANPC, CRHC, is director of education for AAPC.