Hi everyone, this is Dan with ThoroughCare.
CMS published the Final Rule for the Physician
Fee Schedule for what to expect in 2023.
I recently sat down with Carrie Nixon of Nixon Gwilt Law to talk about
all the changes that will be coming as part of the 2023 final rule.
In this video, we'll talk about how the 2023 final rule created
a new program called Chronic Pain Management, or CPM.
Chronic Pain Management.
So this one is brand new for 2023 and the concept of it
managing patients, experiencing pain, that's not a new thing.
You've been doing that for a long time and most providers do.
But this would create a new type of pain model that can include
some of the following elements diagnosing that pain, assessing
and monitoring it, using any type of validated pain rating tool, implementing
care plans that include strength goals, clinical needs, outcomes, overall
treatment management, coordinating care, necessary behavioral health treatment.
So I'm not going to read everything, but these are all the things that CMS
actually lists in the regs here.
There is one requirement.
You can see it at the bottom.
Patients must experience persistent or recurrent pain
lasting longer than three months.
So they have to have at least a three month
history of pain in order to do this program here.
And there are two new codes or codes, as they're often referred to,
and they pay around $79 for the first 1g302
and G three out of three pays around 28 $29. And
we actually it's hard to explain.
So we put the actual text from CMS in here.
But Carrie, I highlighted some of the things in red that I think
are going to stand out to people that first codes 30 minutes
and it says required initial face to face visit.
So the initial 30 minutes, face to face
provided by a physician or provider.
So that can be a tight restriction.
Carrie, you want to talk about that one for a second?
Yeah, and it's even tighter than it may appear on its face
because they mentioned in the rule that in this case,
when they say initial face to face,
they mean in person in a clinical setting.
So no telehealth.
No telehealth visit for the initial first visit.
Okay.
And sometimes, Carrie, we see the word
physician or
authorized health or qualified health professional.
That means like nurse practitioner, right.
It doesn't mean AMA or Erin in this case.
Correct.
That's generally referring
to a physician, nurse practitioner or a physician assistant.
And, you know, so look, this
this codes that step in the right direction for sure.
We we had pointed out previously that our PM kind of leaves out pain
when you're talking
about a physiologic metric because it's and it can't be with RPM,
it can't be self-reported and boy that's generally how you report pain, right?
You self-report it so great that they've put this code set out here.
It's a little it's a little wonky.
It's listed in the telehealth set of codes,
even though the first visit may not be done by telehealth.
The good news is that following visits can be done
virtually by telehealth, even by just audio only. So.
So that is good news.
The barrier really is going to be the requirement
that the physician or practitioner provide these services directly.
And it is one of those you must get 30 minutes.
It's not one of those.
I got 22.
I'm rounding up.
It's 30 minutes or more.
So you have to track the time, You have to log it
and vary provider heavy being that the physician is involved
and actually in both codes, the physician is involved
both the 30 minutes and then the g303 the additional 15 minutes.
That's a provider based code as well. That's correct.
And I think, you know,
where we'd like to get is to the point where a clinical staff could be involved
as well in providing those services and take some of the burden
directly off the practitioner.
The physician.
Yeah.
And like we talked about with our team
when it came out, it was initially direct supervision required.
So this is one of those same thing to a third party group.
And I know we have a lot of them on the call today.
Unfortunately, you're not able to provide this service
for the clinics on the call today.
You as the provider, would have to provide not only in-house,
but do the work or a nurse practitioner or someone provider level
and I thought this was
interesting, Carrie, $79 for a provider's use of 30 minutes.
So I'm not a doctor or a mathematician.
But if if I was a doctor on today's call, I'm thinking to myself,
I could do two inmates
during that same 30 minutes, make a heck of a lot more.
Or I can enroll this patient in chronic care management,
assuming they have two chronic conditions, chronic pain being one.
And my medical assistant or my friend can spend 20 minutes
and make almost as much.
What would you say if someone is thinking that?
Is that how we're reading this?
Carrie I certainly think it's a reasonable,
logical exercise to go through, right?
I mean, you're exactly right, Dan.
I mean, this is in effect certainly the first visit is an in-person visit.
The practitioner or another visit, whether it's by telehealth or not,
still is the length of time right, of a visit, in effect, that a practitioner
could be spending their time at, a physician, a nurse practitioner, pay
know.
I do believe that
the lift is going to come for the practitioners when clinical staff
can participate in this a bit and the mechanism for clinical staff
to participate right now, you're right, Dan, is sort of
the chronic care management services.
There's it's
it's hard to understand why
when we agree that chronic pain is a chronic condition,
one might not use either chronic care management or principal care
management codes to get at a similar
impact and result for the patient
with while utilizing
lower level staff that are going to be escalating up to the practitioner.
So, you know,
your logic is is spot on and hopefully we'll get these kind of improved.
So it might take a couple of years, but for those of you who still want to do
it, this is one program that you can do with others.
So you can do CCI and CPM in the same month.
Remember we said you couldn't do RTM and R.P.M., but this program, at least
that that is an advantage for those who who do want to dive into this in 2023.
That's right for for CPM.
I agree with you, Carrie,
that this is a good first step and we love seeing steps in the right direction.
I think allowing clinical staff to do CPR would be great.
It's very provider intensive at a at a rate that's not really,
you know, equal to the amount of time that a provider would spend.
And unfortunately, I think providers are going to look at this and say,
I could do something else.
So for CPM to be a great program, I think for me, Carrie,
it's allowing the clinical staff to do it, make it gentle supervision
and align the reimbursements, I think better with the quality of work
that's being done. Would you agree with that one?
Definitely. Definitely, yeah.
If you'd like to learn more about what to expect in 23
or other changes to these programs, check out our Learning Center.
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Thanks for watching.