Want a video version of this post? What is comprehensive medication management and how does it differ from continuous medication management? Comprehensive Medication Management is a program created by CMS to be included in the new Comprehensive Primary Care Plus (CPC+) clinic model The CPC+ model was created by MACRA as part of an advanced APM. Now remember in MACRA, there's two different payment tracks that clinics and providers can choose the MIPs route or the advanced APM route. The CPC+ model is application-only and it's only available in certain states and regions. "There are 2,900 primary care practices currently participating in Comprehensive Primary Care Plus (CPC+) in 18 regions: Arkansas, Colorado, Hawaii, Greater Kansas City Region of Kansas and Missouri, Louisiana, Michigan, Montana, Nebraska, North Dakota, Greater Buffalo Region of New York, North Hudson-Capital Region of New York, New Jersey, Ohio and Northern Kentucky Region, Oklahoma, Oregon, Greater Philadelphia Region of Pennsylvania, Rhode Island, and Tennessee." There are two different track models a CPC+ clinic can opt in to. In Track 2, there's an option mentioned to improve care through comprehensive medication monitoring. The idea behind comprehensive medication monitoring is to develop a plan after discharge or for those patients receiving longitudinal care management. There are four primary "change tactics" mentioned in Track 2 of the CPC+ model:
My thoughts for a program that includes a clinical pharmacist like this could include services like:
Providing comprehensive medication management programs and a CPC+ model is an opportunity for consultant pharmacists to help providers and focus on patient care outcomes. If you are interested in building clinical services like comprehensive medication management... Join us on our next LIVE webinar, Sunday, October 21st at 8pmCDT Learn the TOP 3 Mistakes Pharmacists Make in Their Careers and how the Pharmapreneur Academy can help you build the Career of Your Dreams! Register HERE. ABOUT THE AUTHOR: Blair Green Thielemier, PharmD is an independent consultant pharmacist living in Arkansas with her husband and two children. Her latest project is the host and producer of pharmacy’s first virtual conference, the Elevate Pharmacy Virtual Summit in partnership with the NCPA Innovation Center. She is the founder of Pharmapreneur Academy, an online e-Course and Community where she guides pharmacist-entrepreneurs through the process and barriers of building a pharmacy consulting business. She is the author of How to Build a Pharmacy Consulting Business and facilitates in-person Business Planning Workshops and Mastermind Retreats for female Pharmapreneurs across the country. More information about Dr. Thielemier can be found on her website.
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What counts as a transition of care?
Eligibility:
Many time a post-discharge Transitional Care Management Service can be integrated into an existing CCM program. What are the CPT Codes for billing? 99495 ~$164 for non-facility setting ~$135 for facility setting Includes:
99496 ~$231 for non-facility setting ~$197 Includes:
What services a Consultant Pharmacist could offer to patients undergoing Transitions of Care?
How can you put a program like this together? A consultant pharmacist in an off site setting such as a community pharmacy or independent consulting firm could provide the primary touch point for a patient in the 48 hours post discharge. This consultant would need to be engaged in a financial relationship with the physicians office and generally needs to be under a collaborative practice agreement, though not exclusively necessary. Lesson 7 in the E-course at the Pharmapreneur Academy is ALL about the CCM and TCM codes for billing for pharmacist services! If you are interested in building your clinical services... Join us on our next LIVE webinar, Sunday, October 21st at 8pmCDT Learn the TOP 3 Mistakes Most Pharmacists Make in Their Careers and how the Pharmapreneur Academy can help you build the Career of Your Dreams! Register HERE. ABOUT THE AUTHOR: Blair Green Thielemier, PharmD is an independent consultant pharmacist living in Arkansas with her husband and two children. Her latest project is the host and producer of pharmacy’s first virtual conference, the Elevate Pharmacy Virtual Summit in partnership with the NCPA Innovation Center. She is the founder of Pharmapreneur Academy, an online e-Course and Community where she guides pharmacist-entrepreneurs through the process and barriers of building a pharmacy consulting business. She is the author of How to Build a Pharmacy Consulting Business and facilitates in-person Business Planning Workshops and Mastermind Retreats for female Pharmapreneurs across the country. More information about Dr. Thielemier can be found on her website. 
On Saturday, September 22nd, 2018 nine female pharmacists met in Nashville, TN to spend a day together working ON our businesses and identifying ways to support one another.
Masterminding is a concept made famous by Napoleon Hill's classic "How to Think and Grow Rich". Wikipedia describes Masterminding as... A mastermind group is a peer-to-peer mentoring concept used to help members solve their problems with input and advice from the other group members. The concept was coined in 1925 by author Napoleon Hill in his book The Law of Success, and described in more detail in his 1937 book, Think and Grow Rich. In his books, Hill discussed the idea of the Master Mind, which referred to two or more people coming together in harmony to solve problems. Recently, small business owners have taken this concept to a whole new level in the "facilitated Mastermind". A facilitated Mastermind is a formal meeting of entrepreneurs who come together to help each other with their businesses. The best facilitated Masterminds are between 6 & 8 people, diverse enough to support each others strengths and weaknesses and homogeneous enough so that the business owners are at similar points in their business journey. I, myself, have been involved in Masterminds throughout my business journey. In 2016, I participated in a 6 month Mastermind with other women with online businesses. In 2017, I participated in a 9 month Mastermind with other women with 6-figure businesses which were both online and brick and mortar. And this year in 2018, I'm working directly with two other business owners one male, one female who are at the 7-figure business level in hopes to learn from them and grow the impact of the Pharmapreneur Academy. Pharmacy's First Formal Mastermind Event The Female Pharmapreneur Business Development Retreat was pharmacy's first (to my knowledge) facilitated Mastermind ever. Represented by our group was 8 states: Arkansas, California, Colorado, Georgia, Kentucky, Missouri, Oklahoma and Tennessee. Also represented was various specialties, from compounding to non-profit to insurance payers to naturopathic medicine. It was truly a very special group and something I hope to offer again in the near future. I also want to thank Live Oak Bank for sponsoring part of this event and for sharing information with us on the various opportunities for investing in our business and calculating a return-on-investment. 
The structure of the day's agenda:
Upon completion of the Workshop, each attendee was presented with their own copy of the 2019 Business Development Planner, now available on Amazon. Our Homework for the Retreat was to:
Also, we committed to staying focused on actions that move us closer to those goals and give us permission to say "NO" to opportunities that don't align with those goals. As nine women gathered together, we felt the power of diverse backgrounds, diverse ways of thinking and the collective power of the Master Mind. It was truly a magical experience and something I plan to offer again in 2019. If you're interested in our next event, let me know and I'll add you to our waiting list. To stay in contact with all the happenings in the Pharmapreneur Academy Community join our mailing list at BTPharmacyConsulting.com/Newsletter ABOUT THE AUTHOR: Blair Green Thielemier, PharmD is an independent consultant pharmacist living in Arkansas with her husband and two children. Her latest project is the host and producer of pharmacy’s first virtual conference, the Elevate Pharmacy Virtual Summit in partnership with the NCPA Innovation Center. She is the founder of Pharmapreneur Academy, an online e-Course and Community where she guides pharmacist-entrepreneurs through the process and barriers of building a pharmacy consulting business. She is the author of How to Build a Pharmacy Consulting Business and facilitates in-person Business Planning Workshops and Mastermind Retreats for female Pharmapreneurs across the country. More information about Dr. Thielemier can be found on her website. 
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Medicare Part B covers medical nutrition therapy (MNT) services and some related services that integrate nicely with what a Consultant Pharmacist can offer.
However, MNT must be provided by a registered dietitian or a nutritional professional who meets certain requirements. This is a GREAT option for pharmacists who also have a professional background in nutrition. Even though MNT can only be provided by a nutrition professional, it still MUST be ordered by a doctor. MNT services may include:
A pharmacist with a nutrition degree could provide MNT services as an off-site consultant. For patients being treated in a dialysis facility, Medicare covers MNT as part of your overall dialysis care. Codes and Criteria: 97802 – MNT; initial assessment and intervention, individual, face-to-face with the patient, each 15 minutes 97803 – MNT; re-assessment and intervention, individual, face-to-face with the patient each 15 minutes 97804 – MNT; group (2 or more individual(s)), each 30 minutes G0270 – MNT reassessment and subsequent intervention(s) for change in diagnosis, individual, each 15 minutes G0271 – MNT reassessment and subsequent intervention(s) for change in diagnosis, group (2 or more), each 30 minutes
How you can utilize this code: MNT should not be confused with diabetes self-management training (DSMT), however. DSMT is an education and training program that helps patients manage their diabetes, whereas MNT consists of more individualized diagnosis, therapy, and counseling related to nutrition. According to the American Dietetic Association's 2009 White Paper on Nutrition Services that distinguishes between the delivery of DSMT and MNT services, the DSMT curriculum that is accredited by Medicare consists of 1 hour of individualized assessment and 9 hours of group classes. DSMT curriculum is focused on “incorporating nutritional management into lifestyle,” and “using medications safely and for maximum therapeutic effectiveness.” Sometimes it may be most helpful for patients to receive DSMT first, followed by MNT. Other patients may receive DSMT and MNT simultaneously. A consultant pharmacist may partner with a nutritional professional to offer a collaborative DSMT/MNT program. What services are you implementing in 2019? Leave me a note in the comments or join our Pharmapreneur Community Newsletter and email me directly! ABOUT THE AUTHOR: Blair Green Thielemier, PharmD is an independent consultant pharmacist living in Arkansas with her husband and two children. Her latest project is the host and producer of pharmacy’s first virtual conference, the Elevate Pharmacy Virtual Summit in partnership with the NCPA Innovation Center. She is the founder of Pharmapreneur Academy, an online e-Course and Community where she guides pharmacist-entrepreneurs through the process and barriers of building a pharmacy consulting business. She is the author of How to Build a Pharmacy Consulting Business and facilitates in-person Business Planning Workshops and Mastermind Retreats for female Pharmapreneurs across the country. More information about Dr. Thielemier can be found on her website. 
Want a video version of this post? I've got you covered! Diabetes self-management training (DSMT) is an education program that can be provided to eligible newly diagnosed Medicare beneficiaries. Patients are eligible for 10 hours within the first year of diagnosis and then 2 hours each year thereafter. Education can be provided via group sessions (> 2 patients) or individually, though individual education must be justified. CPT Codes G0108, individual, per 30 minutes and G0109, group session, per 30 minutes Criteria
Eligibility Who Is Covered? Certain Medicare beneficiaries when all of the following are true:
Frequency? Initial year: Up to 10 hours of initial training within a continuous 12-month period Subsequent years: Up to 2 hours of follow-up training each year after the initial year
Opportunities for Consultant Pharmacists to Use the Codes DSMT probably has the most difficult criteria to meet since the organization must be accredited by either the ADA or AADE. However, overall gaining accreditation isn’t too difficult and if you are partnering with a provider who sees many diabetic patients helping them gain accreditation opens up an additional revenue stream. Once accreditation has been established you can partner with the physician to provide DSMT. Remember, DSMT must be ordered by the provider first. Then the pharmacist can deliver the service. It does not require a collaborative practice agreement unless you are making changes to the patients therapies. Just as with the diabetes prevention programs, if monitoring patient data such as blood sugar, weight, or physical activity electronically you can also utilize the remote patient monitoring code. The next opportunity we'll discuss is Medical Nutrition Therapy. Sign up for the Pharmapreneur Community Newsletter and get it delivered directly to your Inbox! ABOUT THE AUTHOR: Amy Henneman, PharmD, BCACP, BCPS, CDE is an associate professor of pharmacy practice living in south Florida with her husband and two children. Her practice has been focused in building ambulatory care services and working to provide expanded care to low income patients. She enjoys working with both providers and other pharmacists to assist them in offering expanded pharmacy services. 
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Remote Patient Monitoring: An Opportunity for Consultant Pharmacists?
Effective January 1st, 2018, the Centers for Medicare and Medicaid Services will begin reimbursing for remote patient monitoring (RPM). So, what is RPM? For starters, NOT telehealth services, which is actually a good thing. While telehealth services do exist, they have several specifications that can make widespread use a little tricky. So what about RPM? RPM is the use of digital technology to collect health data from a patient that is then transmitted electronically and securely to a healthcare provider in another location for assessment and recommendation. CMS is now going to reimburse providers for that assessment and recommendation portion, if it constitutes at least 30 minutes of provider time per month, using CPT 99091. This means for those patients participating in home glucose or blood pressure monitoring, INR, and even potentially genetic reports, the provider now has the opportunity to receive approximately $60 per month for their time spent reviewing, assessing, and making recommendations regarding the patient’s care plan. So what are the specifications? Most notable is that CMS stated the service must be provided by the practitioner, not clinical staff. For now, using this code means utilizing incident to billing. Consent must be obtained and documented from the patient, and for all new patients or those that have not been seen within the last 12 months, they must have an initial visit. The code can be billed once per month for each patient as long as the practitioner is receiving information electronically that impacts the patient’s care. This opens another potential revenue stream for savvy Pharmapreneurs. For pharmacists partnering with physicians to offer MTM or consulting services who meet the criteria for incident to billing, this is another service you can offer to your providers. If you are already spending time reviewing medications and/or making adjustments to medications, most likely this service is an extension of what you are already doing. Before making a recommendation or an adjustment to a patient’s insulin regimen, you probably want to see the patient's blood sugar logs. If the patient is able to send them electronically, there’s an opportunity to utilize RPM. If you are already using the chronic care management codes (CPT codes 99487, 99489, and 99490), RPM can be billed in conjunction with these. As CMS moves towards innovation and expanded integration of technology, this means big opportunities to be on the forefront of this move forward. Remote Patient Care Monitoring is the use of digital technology to collect health data from a patient that is then transmitted electronically and securely to a healthcare provider in another location for assessment and recommendation. CPT Code 99091 The Center for Medicare and Medicaid Services (CMS) reimburses providers for that assessment and recommendation portion, if it constitutes at least 30 minutes of provider time per month. Billing Criteria The service must be provided by the practitioner, not clinical staff. So for now, using this code means utilizing incident to billing. Consent must be obtained and documented from the patient, and for all new patients or those that have not been seen within the last 12 months, they must have an initial visit. The code can be billed once per month for each patient as long as the practitioner is receiving information electronically that impacts the patient’s care. Information transmitted electronically must be transmitted in a protected manner. Opportunities for Consultant Pharmacists For pharmacists partnering with physicians to offer MTM or consulting services who meet the criteria for incident to billing, this is another service you can offer to your providers. If you’re thinking diabetes management the first thing you should think of is blood sugar monitoring. Home blood sugar monitoring is necessary for most patients and something we ask for often. This information could be transmitted electronically and the time you spend reviewing the information billed for using this code. Additionally, if you partner with a provider to offer a diabetes prevention program or diabetes self-management training, electronic transmission of items such as patient weight and physical activity could also qualify for remote patient monitoring, giving you more bang for your time. The next opportunity we'll discuss is remote patient monitoring. Sign up for the Pharmapreneur Community Newsletter and get it delivered directly to your Inbox! ABOUT THE AUTHOR: Amy Henneman, PharmD, BCACP, BCPS, CDE is an associate professor of pharmacy practice living in south Florida with her husband and two children. Her practice has been focused in building ambulatory care services and working to provide expanded care to low income patients. She enjoys working with both providers and other pharmacists to assist them in offering expanded pharmacy services. 
Want a video of this content? Opportunity for Consultants: National Diabetes Prevention Program While this program has been around for many years, it has only been since 2016 that these programs have been billable under Medicare. So, what is a diabetes prevention program? Simply, it is a lifestyle change program intended to prevent or delay the onset of type 2 diabetes. While there are many lifestyle change programs available in many communities, the ones that are eligible for reimbursement under Medicare are ones that are recognized by the Centers for Disease Control and Prevention (CDC). Code: G code, G9873 - 9885 So what do you need to know: National Diabetes Prevention Programs can be offered by any individual or organization as long as they meet criteria to become a CDC recognized provider. CDC criteria include the following:
Ability to track participants progress (ex: physical activity, weight, etc.) which must be reported to the CDC to maintain recognition status. How can you take advantage of this opportunity? Because these codes do not have to be linked to a specific type of organization or healthcare provider, you can use these codes in a variety of settings as long as the patient meets eligibility criteria. You could contract with a provider to offer these services to a groups of patients on a rolling basis. In a retail setting, you could offer group classes. As a pharmapreneur you can start a class in your community or develop online content for your audience. Really, with this one, the sky is the limit as long as you can meet the CDC criteria and track outcomes. Another huge benefit of this is that the enrollment is a minimum of 1 year, which allows you to track and monitor your patient outcomes long term. The next opportunity we'll discuss is remote patient monitoring. Sign up for the Pharmapreneur Community Newsletter and get it delivered directly to your Inbox! ABOUT THE AUTHOR: Amy Henneman, PharmD, BCACP, BCPS, CDE is an associate professor of pharmacy practice living in south Florida with her husband and two children. Her practice has been focused in building ambulatory care services and working to provide expanded care to low income patients. She enjoys working with both providers and other pharmacists to assist them in offering expanded pharmacy services. 
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Definition
Medicare covers a yearly appointment to discuss your plan of preventive care in the coming year. This appointment is called the Annual Wellness Visit (AWV). The Annual Wellness Visit is similar to the one-time Welcome to Medicare preventive visit but has important differences. For example, like the Welcome to Medicare visit, the Annual Wellness Visit (Initial Preventative Physical Examination) is not a head-to-toe physical. However, you cannot receive your Annual Wellness Visit within the first year you are enrolled in Medicare or within the same year you have your Welcome to Medicare exam. CPT Codes G0438 - Initial AWW - includes a personalized prevention plan of service (PPPS) G0439 - Subsequent AWV - updates a personalized prevention plan of service (PPPS) Components Initial AWV
Components Subsequent AWV
Opportunities for additional preventative services
Provider can bill for G0506 in addition to the AWV/IPPE billing Comprehensive assessment of and care planning by the physician or other qualified health care professional for patients requiring chronic care management services (billed separately from monthly care management services and MAY BE ADDED TO AN AWV- but must be seen by a QHCP). The G0506 code is particularly appropriate when the CCM initiating visit is a less complex visit (such as a level 2 or 3 E/M visit). G0506 can be billed along with higher level E&M visits if the practitioner’s effort and time exceeded the usual effort described in the initial visit E&M code. G0506 can also be billed when the initiating E&M visit addresses problems unrelated to Chronic Care Management and the CCM related work is not included in the initial visit code. Could be face-to-face and/or non-face-to-face, but the time spent doing the CCM care planning must not already be reflected in the CCM initiating visit itself or in the time spent during the monthly CCM (i.e., in CPT 99490, CPT 99487, CPT 99489) G0506 is meant to be billed only once per beneficiary during the initiation of the patient into Chronic Care Management. What services are you implementing in 2019? Leave me a note in the comments or join our Pharmapreneur Community Newsletter and email me directly! ABOUT THE AUTHOR: Blair Green Thielemier, PharmD is an independent consultant pharmacist living in Arkansas with her husband and two children. Her latest project is the host and producer of pharmacy’s first virtual conference, the Elevate Pharmacy Virtual Summit in partnership with the NCPA Innovation Center. She is the founder of Pharmapreneur Academy, an online e-Course and Community where she guides pharmacist-entrepreneurs through the process and barriers of building a pharmacy consulting business. She is the author of How to Build a Pharmacy Consulting Business and facilitates in-person Business Planning Workshops and Mastermind Retreats for female Pharmapreneurs across the country. More information about Dr. Thielemier can be found on her website. 
Would you like to watch a video version of this post? I've got you covered! Chronic Care Management Services Medicare is rewarding new processes aimed at improving patient care and reducing healthcare expenses. One new program that became eligible for physician reimbursement is a program intended to monitor certain patients with multiple chronic conditions. As of January 1, 2015, Medicare is paying for a non-face-to-face care coordination service through use of billing code 99490. The Chronic Care Management Services may be provided by phone or tele-health by a qualified health care professional under the physician’s general supervision. The service is usually offered as a 20 minute contact once every calendar month. An estimation provided by this CCM calculator shows that just 50 enrolled patients could equate to an additional $25,560 in revenue for the practice each year. This is a relatively new program that an entrepreneurial pharmacist could easily implement for multiple physician groups in their area for a fee. Eligibility Multiple (two or more) chronic conditions expected to last at least 12 months, or until the death of the patient Chronic conditions place the patient at significant risk of death, acute exacerbation/decompensation, or functional decline Comprehensive care plan established, implemented, revised, or monitored CMS requires the billing practitioner to furnish one of the following. Prior to billing the CCM service, and to initiate the CCM service as part Patient Agreement of this visit/exam.
12 Components of CCM
CPT Codes The two key differentiators between 99487 and 99490 are the additional time (60 minutes for CPT 99487 from 20 minutes for CPT 99490) and the requirement around medical decision making. In addition, a code reimbursing for additional time (CPT 99489) is available for complex CCM patients being billed under CPT 99487. Provider can bill for G0506 in addition to the AWV/IPPE billing Comprehensive assessment of and care planning by the physician or other qualified health care professional for patients requiring chronic care management services (billed separately from monthly care management services and MAY BE ADDED TO AN AWV- but must be seen by a QHCP) The G0506 code is particularly appropriate when the CCM initiating visit is a less complex visit (such as a level 2 or 3 E/M visit). G0506 can be billed along with higher level E&M visits if the practitioner’s effort and time exceeded the usual effort described in the initial visit E&M code. G0506 can also be billed when the initiating E&M visit addresses problems unrelated to Chronic Care Management and the CCM related work is not included in the initial visit code. Could be face-to-face and/or non-face-to-face, but the time spent doing the CCM care planning must not already be reflected in the CCM initiating visit itself or in the time spent during the monthly CCM (i.e., in CPT 99490, CPT 99487, CPT 99489) G0506 is meant to be billed only once per beneficiary during the initiation of the patient into Chronic Care Management. What do are your thoughts? Would this be a viable business model in your area? Leave a comment below. Leave me a note in the comments or join our Pharmapreneur Community Newsletter and email me directly! ABOUT THE AUTHOR: Blair Green Thielemier, PharmD is an independent consultant pharmacist living in Arkansas with her husband and two children. Her latest project is the host and producer of pharmacy’s first virtual conference, the Elevate Pharmacy Virtual Summit in partnership with the NCPA Innovation Center. She is the founder of Pharmapreneur Academy, an online e-Course and Community where she guides pharmacist-entrepreneurs through the process and barriers of building a pharmacy consulting business. She is the author of How to Build a Pharmacy Consulting Business and facilitates in-person Business Planning Workshops and Mastermind Retreats for female Pharmapreneurs across the country. More information about Dr. Thielemier can be found on her website. 
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One of the most frequently asked questions I get about billing for pharmacist services is "How can a consultant pharmacist use the incident to billing codes in an ambulatory care clinic?"
The easy rule of thumb is to know whether that service is beholden to the direct supervision (aka. Incident-to criteria) or the general supervision requirements. When implementing a new service as a consultant pharmacist there are a few things to keep in mind regarding the supervision of auxiliary personnel. 1. Incident to billing codes use must fit incident to billing requirements for direct supervision These services must be performed under direct supervision – The physician must be in the office suite/building.
2. Billed at 100% physician's fee schedule and must be face-to-face. 99211 - nurses' visit - 5 minutes - no medical decision making 99212 - 10 minutes - straightforward/little to no medical decision making 99213 - 15 minutes - low level of medical decision making 99214 - 25 minutes - moderate level of medical decision making 3. Different Medicare Administrative Contractors (MACs) have different requirements regarding auxiliary or non-physician personnel. Also check your state pharmacy practice act and the language around collaborative practice agreements CONCLUSION Consultant pharmacists can use the incident to CPT codes 99211-99124 to bill through the physician's NPI under the direct supervision of a collaborative physician if the MAC and state's pharmacist scope of practice act allows for it. What services are you dreaming of implementing in 2019? Leave me a note in the comments or join our Pharmapreneur Community Newsletter and email me directly! ABOUT THE AUTHOR: Blair Green Thielemier, PharmD is an independent consultant pharmacist living in Arkansas with her husband and two children. Her latest project is the host and producer of pharmacy’s first virtual conference, the Elevate Pharmacy Virtual Summit in partnership with the NCPA Innovation Center. She is the founder of Pharmapreneur Academy, an online e-Course and Community where she guides pharmacist-entrepreneurs through the process and barriers of building a pharmacy consulting business. She is the author of How to Build a Pharmacy Consulting Business and facilitates in-person Business Planning Workshops and Mastermind Retreats for female Pharmapreneurs across the country. More information about Dr. Thielemier can be found on her website. |
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