Coordinating Care Transitions

1. What was the admission diagnosis and discharge date? Default: [REQUIRED]
2. Has the discharge summary been received and reviewed? Default: pending
3. Was the initial interactive contact (phone/telehealth) made within 2 business days of discharge? Default: schedule
4. What is the target for face-to-face visit (within 7 days for high complexity, 14 days for moderate)? Default: assess complexity
5. What medications were changed during the hospitalization (new, adjusted, discontinued)? Default: per discharge summary
6. Does the patient have home health, skilled nursing, or other post-acute services ordered? Default: per discharge plan
7. Is there a caregiver or family member involved in the transition? Default: identify
8. What pending test results or follow-up appointments were listed in the discharge summary? Default: review

Documents to Request

• Hospital discharge summary (must include: diagnoses, procedures, medication reconciliation, follow-up instructions, pending results)
• Inpatient medication administration record (MAR)
• Discharge medication list compared to pre-admission medication list
• Nursing discharge notes (functional status, patient education provided)
• Consultant notes from hospitalization
• Pending lab/imaging results at time of discharge
• Home health or SNF orders
• Patient's pre-hospitalization medication list from PCP records
• DME orders (oxygen, CPAP, wound care supplies)
• Social work or case management discharge assessment

Step 1: Initial Contact Within 2 Business Days

CMS requires interactive contact within 2 business days of discharge for TCM billing:

Phone or telehealth contact checklist:

• Confirm patient is at home (or current location) and stable
• Review discharge diagnosis and ensure patient understanding
• Assess for red flag symptoms requiring immediate evaluation:
  • Chest pain, severe SOB, high fever, wound dehiscence, altered mental status
  • Inability to take medications due to nausea/vomiting/cost
  • Worsening of the condition that prompted hospitalization
• Confirm patient has discharge medications in hand (physically obtained from pharmacy)
• Identify medication questions or confusion
• Confirm follow-up appointments scheduled (PCP, specialists)
• Assess home safety and support (caregiver availability, food, mobility)
• Schedule face-to-face visit (within 7 or 14 days depending on complexity)

Document: date, time, who was contacted, method (phone/video), findings, and plan.

Step 2: Comprehensive Medication Reconciliation

This is the single highest-impact intervention for preventing readmission:

Generate a reconciled medication list with disposition for each drug: CONTINUE (unchanged), NEW (started in hospital), CHANGED (dose adjusted), STOPPED (discontinued with reason), HOLD (temporarily suspended).

Step 3: Face-to-Face TCM Visit

Structure the TCM visit to capture all required elements for CPT 99495/99496:

Medical decision-making components:

• Review discharge summary findings with patient
• Focused physical exam relevant to hospitalization diagnosis
• Review and finalize medication reconciliation
• Assess functional status compared to baseline
• Address pending test results from hospitalization
• Update problem list and diagnoses

Condition-specific follow-up protocols:

Step 4: Care Coordination and Communication

High-risk patient identification for intensive follow-up:

• LACE index (Length of stay, Acuity, Comorbidities, ED visits): score ≥10 = high readmission risk
• HOSPITAL score: ≥7 = high risk
• Patients with HF, COPD, AMI, pneumonia, hip/knee surgery (HRRP conditions)
• Patients with ≥3 chronic conditions, polypharmacy (≥10 medications), or lack of social support

Step 5: TCM Billing Documentation

Required documentation elements:

1. Date of discharge from facility
2. Date and method of interactive contact within 2 business days
3. Date of face-to-face visit
4. Medical decision complexity (moderate or high) with supporting documentation
5. Medication reconciliation documented with comparison of discharge vs. current list
6. Care coordination activities performed (referrals, communication with specialists/facilities)
7. Medical services provided during the 30-day TCM period

Billing rules:

• Only one provider can bill TCM per patient per 30-day period
• TCM cannot be billed if the patient is readmitted within the 30-day period before the face-to-face visit
• TCM is payable by Medicare, most Medicaid, and many commercial payers
• TCM is billable for discharge from hospital, SNF, LTAC, IRF, or psychiatric facility (not observation stays for some payers)

Checkpoint B: Post-Draft Alignment (Mandatory)

1. Was the initial interactive contact made within 2 business days of discharge?
2. Is the complete medication reconciliation documented with disposition for every medication?
3. Did the face-to-face visit occur within the appropriate window (7 or 14 days)?
4. Are all pending results from the hospitalization tracked with follow-up plan?
5. Is the TCM billing documentation complete with all required elements?

Quality Audit

• Discharge summary received and reviewed by PCP within 48 hours of discharge
• Interactive contact completed within 2 business days (date, time, method documented)
• Red flag symptoms screened during initial contact
• Patient confirmed to have discharge medications in hand
• Medication reconciliation completed: every medication has a disposition (continue, new, changed, stopped, hold)
• Drug duplications and interactions identified and resolved
• Face-to-face visit completed within 7 days (99496) or 14 days (99495)
• Condition-specific follow-up protocol applied
• Pending test results tracked with responsible party and timeline
• Specialist follow-up appointments scheduled per discharge recommendations
• Home health/SNF communication completed if applicable
• Readmission risk assessed (LACE or HOSPITAL score)
• TCM billing requirements documented (all required elements present)
• 30-day post-discharge period care plan documented

Guidelines

• Never assume the discharge medication list is correct; always compare against the pre-admission list and clarify discrepancies with the discharging team
• The 2-business-day interactive contact is a hard CMS requirement for TCM billing; a voicemail or portal message does NOT count—it must be an interactive exchange (live phone, video, or in-person)
• High-complexity TCM (99496) requires both high-complexity MDM and a face-to-face visit within 7 days; do not upcode if either criterion is unmet
• Medication reconciliation must be documented as a distinct activity, not just a medication list in the chart; show the comparison and decisions made for each medication
• Heart failure patients discharged on new or adjusted diuretics/ACEi/ARB require a BMP within 3-7 days to check potassium and creatinine; this is the most commonly missed post-discharge lab
• Patients discharged on anticoagulants (especially new starts) require INR check within 3-5 days (warfarin) or renal function monitoring (DOACs) and bleeding precaution education
• If the discharge summary has not been received within 48 hours, actively contact the discharging facility; do not wait for it to arrive passively
• Document all care coordination activities (phone calls, faxes, referrals, communications) with date, time, and content summary to support TCM billing