The Centers for Medicare and Medicaid Services (CMS) profitable programs are incredibly valuable, yet they sometimes are just as confusing.

Many Medicare schemes allow or require the provision of non-face-to-face services, which is frequently a gray area with no clear definition.

Chronic Care Management, for example, involves care coordination activities that aren’t usually part of a face-to-face meeting with a patient. These activities include:

• Phone conversations
• Evaluation of medical records
• Education and support
• Coordination and exchange of health information with other practitioners and health care experts

We’ve worked with hundreds of healthcare practitioners. Around the country and have heard questions and concerns regarding non-face-to-face contact time after again.

Many practices have benefited from our sales reps and support. Staff’s assistance in navigating the rules and regulations of Medicare programs, allowing them to focus on their patients.

This guidance is based on a collection of best practices from leading providers we’ve collaborated with over the years.

“What defines non-face-to-face time?” is one of the most often asked questions. And “Who is allowed to devote this time to patient care?”

This article will answer these concerns and go over the top five gray areas that providers encounter while documenting non-face-to-face time.

What Does Non-Face-to-Face Time Entail?

Medicare’s regulations for various programs do not have a set task list. We ask that you exercise your best judgment in cases where your interpretation is left up to you.

Our advice is never to do something that makes you feel uneasy. If you believe you can justify billing for non-face-to-face time spent on the patient’s treatment, go ahead.

Who Can Provide Non-Face-to-Face Time?

A patient’s care will involve encounters with a number of clinical and non-clinical people.

According to CMS standards, only time spent by certified resources (e.g., Certified Medical Assistant, Certified Nursing Assistant, or higher) should be counted toward non-face-to-face billable time.

So, if a non-clinical resource performed a task, we recommend not counting that time.

The only exception is if the CMS standards for the program enable non-clinical workers to provide care in any way.

To help you understand better, we’ll go over the five most common gray areas for reporting non-face-to-face time for Medicare purposes.

1.  No Answer/Voicemails

Talking to the patient over the phone is one of the most popular activities for numerous Medicare programs. A care manager’s day is mainly spent chatting on the phone with patients. Naturally, getting in touch with the patient can be challenging at times.

Should the time spent leaving a message for the patient be counted as time spent caring for the patient that month? Well, that is debatable.

Only count down the minutes while leaving a message if you provide critical information about a patient’s health (i.e., lab results, medication info).

We do not recommend keeping track of the time spent waiting for the patient to answer or leaving non-clinical information on a voicemail.

2.  Emails / Text Messages

We’re seeing increasing communication between the care team and the patient via email and text as Medicare patients grow more tech-savvy.

While this may appear to be a routine task, it can nonetheless be used to bill the patient.

We suggest keeping track of the time it takes to compose the message and any follow-up emails or texts sent afterward.

3.  Action Items / Post-Call Notes

You may need to update and document various patient data in your care management software and/or your EHR when your patient calls are completed.

This could include details you missed or didn’t have time to ask about during your call. This time spent documenting post-call notes and data should be factored into your patient’s monthly billing time.

4.  Enrollment in the program

Enrolling patients is crucial for running a long-term and viable Medicare program. Unfortunately, once a patient accepts participating in the Medicare program, all of their time is counted.

Any time spent managing the patient’s care can be billed as non-face-to-face time once the patient has enrolled.

5.  Face-to-Face Time

Most Medicare programs have traditionally solely counted non-face-to-face time spent with patients. If time is offered face-to-face regularly for convenience or other reasons, it may be counted toward the program and billed accordingly.

Take CCM, for example. According to Medicare’s explanation, “If the practitioner believes that a given beneficiary would benefit or participate more in person, or for similar reasons. recommends that a certain beneficiary receive certain CCM services in person, the activity may still be billed. In all circumstances, if time and effort are credited to CCM, they cannot be applied to any other code.”

When logging face-to-face time, just like you would non-face-to-face time, use your best judgment. In this case, you’ll also want to make sure you’re not billing CCM and another billable CPT code simultaneously.

If you’d like to learn more about CCM Health’s Chronic Care Management and how it can benefit your practice, book a meeting with us today here!