Reimbursability of Non-Complex Chronic Care Management (CCM)

This article will discuss the reimbursability of Non-complex Chronic Care Management (CCM), a non-face-to-face service. It also discusses the documentation requirements and risks associated with non-face-to-face services. This article will also explain the two codes for CCM and their differences from traditional face-to-face services. The article will also address common billing questions. It is important to note that the two codes for CCM are reimbursable when they are used in the context of a primary care office visit.
Non-complex Chronic Care Management (CCM) is a non-face-to-face service

CCM is a non-face-to face health care service that is generally provided to Medicare beneficiaries with one or more chronic conditions that place them at high risk of decompensation, death, or serious functional decline. This service is provided under the supervision of a physician and is separately payable. CMS does not set a standard list of chronic conditions, but offers a brief summary of conditions that may qualify. There is a databank of chronic conditions that the government uses, but this list is not exhaustive. The decision on what qualifies as a CCM service is left up to the treating physician, who must provide complete chart documentation and develop a detailed care plan.

CCM services require patient consent. The patient must consent in advance. Before initiating CCM services, a patient must provide verbal consent. Informed consent must include the right to withdraw or revoke consent at any time. Medicare does not reimburse two practitioners for CCM services in the same month, and a patient may revoke consent at any time.

Codes 99358 and 99359 are reimbursable

The codes 99358 and 99359 are reimbursable for nonface-to-face services. These codes represent extensive time spent outside the office without the patient, and must relate to ongoing patient management. The codes are not add-ons, but must be reported on the same day as the primary E/M code. These codes are not reported for office staff time, but rather time spent in the patient’s bedside. It is also important to note that the service does not necessarily have to be continuous.

The CPT instructions state that the CPT codes 99358 and 99359) are reimbursable for nonface-to-face services. There is no upper time limit for reporting these services, but the CMS expects that time over the threshold should be reported under the appropriate CPT codes. In order to avoid confusion and overpayments, you should carefully review the CPT instructions to determine whether you can report these services.

Documentation requirements

For E/M visits, documentation should show the start and stop times of the visit. It must also show that the provider spent a minimum of 31 minutes performing a service that was directly related to the patient’s condition. The documentation should be legible and include the name of the servicing provider. There are some exceptions, however. Here are some important examples. In order to meet the documentation requirements for E/M visits, you should document all of the following:

Generally, you cannot bill for time that is not directly related to the patient. This means that you can bill for the time you spend managing the patient’s condition. CMS has made an exception for non-face-to-face services. In addition to recognizing existing CPT(r) codes, CMS is developing new ones for these management services. The non-face-to-face service category includes 99358 Prolonged evaluation and management before or after direct patient care. You can bill this code separately or with another CPT code.


In order to avoid impersonation, financial institutions should implement additional measures to verify customer identity when providing non-face-to-face service. These measures can include providing electronic copies of identification documents or real-time video conferences. The Circular also points to best practices in non-face-to-face customer onboarding. But it’s important to note that a non-face-to-face customer onboarding procedure can still be risky.

The Financial and Capital Market Commission (FCMC) has made recommendations on risks related to non-face-to-face customer identification. These recommendations seek to foster a unified understanding of these risks, establish requirements for implementing these procedures, and prevent the institution from being involved or attempted to be involved in money laundering. The recommendations also clarify measures provided in normative acts and regulations to implement non-face-to-face customer identification.