Home Health & Hospice Week

But final usage remains up in the air.

Many hospices will be glad to see official recognition of their hospice chaplain costs, although that could still be a ways off.

The Centers for Medicare & Medicaid Services HCPCS committee has approved three billing codes for chaplain services, report the National Hospice and Palliative Care Organization and the National Association for Home Care & Hospice: HCPCS Level II code Q9001 (Assessment by chaplain services); HCPCS Level II code Q9002 (Counseling, individual, by chaplain services); and HCPCS Level II code Q9003 (Counseling, group, by chaplain services).

“This is a positive first step towards meeting the requests of hospices and stakeholders for [CMS] to begin collecting data on chaplain services delivered to hospice beneficiaries,” NAHC cheers in its member newsletter. “Currently, CMS collects data on all other core disciplines in hospice — physician, registered nurse, medical social worker — except chaplains (pastoral counselors) via hospice claims,” the trade group notes.

Medicare Advantage plans reimbursing for chaplain services gave CMS the reimbursement reason it needed to approve the codes, NHPCO says in a regulatory alert.

However: “It is not clear if or when CMS will utilize these codes on hospice claims or as part of the [Hospice Quality Reporting Program],” NAHC notes. “Hospices should not utilize the newly approved codes until CMS provides instruction to do so,” the trade group cautions

The new codes aren’t exactly a surprise, judges M. Aaron Little with FORVIS in Springfield, Missouri. “It’s been expected for some time that CMS was working on some kind of a solution for capturing chaplain service utilization beyond just the cost data available on the cost report,” Little says.

But “before the new HCPCS codes can be used on claims, CMS would need to either create a chaplain revenue code or designate an existing revenue code to be used for chaplain services,” Little points out. “To my knowledge that has not yet been done, making it difficult to predict how and when these new HCPCS codes will be used,” he concludes.