Pershing, Yoakley & Associates and Enli Health Intelligence have recently released the results of a new survey entitled “The National Chronic Care Management Survey 2015.” This survey provides insights into the difficulties early adopters have encountered with efforts to implement CMS’s new Chronic Care Management program. According to the survey, early adopters are struggling with (1) physician engagement, (2) patient education, (3) efficient processes, and (4) regulatory compliance. The following paragraphs contain my commentary related to points 3 & 4. To be redirected to the PYA website and a link to view their publication, click here: http://www.pyapc.com/chronic-care-management-survey-released/
And the survey said…less than 10% of the practices who have implemented a CCM program in 2015 considered outsourcing the process to a care management company such as CareSync (http://www.caresync.com/ccm/) or one of the other “full-service” solution providers. That means greater than 90% of the practices offering CCM are relying upon internally developed processes and/or programs to fulfill the rather onerous regulations imposed by CMS to be allowed to compliantly bill for the services provided. These internally developed and managed CCM programs are probably the leading cause for the extremely poor enrollment figures. According to the most recently published data, out of approximately 35 million CCM eligible patients, CMS indicates that only 100,000 patients have been enrolled thus far. And the PYA survey reveals that less than 50% of providers who are offering CCM have “successfully billed and received payment for CCM services furnished to eligible Medicare beneficiaries.” Clearly, internally developed and managed CCM programs for the most part are not working well for providers. More importantly, the programs are not working well for patients.
So why are enrollment numbers so low, and why have so few claims been paid?
The PYA survey data gives us some clues. One of the major obstacles to a successful CCM program is limitations associated with the provider’s EHR system – their programs simply were not initially designed with CCM compliance requirements in mind. Although many EHR providers have developed or are in the process of developing add on modules designed to facilitate CCM time-tracking requirements, care plan development and other required CCM components, they are for the most part “provider centric” rather than “patient centric,” and they do little to foster patient engagement in CCM.
Another reason most internally managed CCM programs are not working well is due to providers’ assumption that they can fulfill the scope of services required by allocating 20 minutes of staff time per month for each CCM patient. Technically 20 minutes is all that is required, but practices offering CCM services simply have not been able to fulfill the scope of services within that time frame. Respondents to the PYA survey indicate that the median time required to fulfill all of the scope of services is in excess of 35 minutes per patient – nearly twice their anticipated and budgeted time.
That data correlates well with data from CareSync, a leading CCM solution provider. They have enrolled and enabled their CCM clients to compliantly bill and receive monthly reimbursements for nearly 20,000 patients, and their data suggests that the required minimum 20 minutes is an inadequate amount of time to properly fulfill the scope of services required. The chart below identifies the amount of time their care coordinators actually spent on each CCM patient during the patients’ initial 90 days of services.
Based upon the real-life experience from successful programs, providers should consider 40-45 minutes per patient per month as the minimum time required to implement a successful CCM program – a program that will provide patients with the intended benefits.
Is it possible to have a successful program based upon the minimum requirement of 20 minutes per month?
Possibly, but thus far the data does not seem favorable. Providers might be able to fulfill the technical requirements of the program within that amount of time, but it is unlikely that the scope of services needed to provide true patient benefits can be accomplished in 20 minutes.