This article provides answers to some frequently asked questions about reporting transitional care management (TCM) services. For more information on TCM services, please see “Transitional Care Management: Revisiting the Basics” elsewhere in this newsletter.

This depends on the payer. Current Procedural Terminology (CPT®) prefatory text indicates that activities are performed by the reporting physician or other QHP and/or “licensed clinical staff.” However, an inquiry to the American Medical Association CPT staff asking if clinical staff must be licensed was answered by stating that CPT provides a definition of clinical staff and, beyond that, CPT only defines the services that must be performed to report the code—not the licensure of the individual performing the service. Physicians are responsible for ensuring that tasks that are provided under their supervision are appropriate to the level of training of the clinical staff member providing the service and allowed under state regulations....

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