Hospices Welcome Expanded Chaplain Services Codes, Seek Clarity on Applicability

Hospices are seeking greater clarity on updated Medicare rules that allow hospices to document a broader range of chaplain services on claims.

The U.S. Centers for Medicare & Medicaid Services’ (CMS) recently revised three existing items in the Healthcare Common Procedure Coding System (HCPCS), eliminating languages that limited their use to the health care arm of the U.S. Department of Veteran Affairs (VA).

The revised codes allow hospice providers include an expanded scope of chaplain services on claims submitted to private insurers and Medicaid agencies, but do not apply to hospice Medicare claims due to the bundled payment structure.

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“The revised codes make available standard language for use to report chaplain services for assessment, individual counseling and group counseling on medical claims to insurers, when such data reporting and collection is consistent with the policies and programmatic needs of the insurer in whose jurisdiction a claim would be filed,” a CMS spokesperson told Hospice News in an email.  

The existence of the HCPCS codes does not confer coverage or payment on the part of any insurer, the spokesperson added.

The updates bring CMS one step closer to standardizing claims reporting for those services. This could potentially also pave the way for new quality measures around spiritual care, according to Kyle Christiansen, membership and marketing manager at the Association of Professional Chaplains (APC).

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“Insurers will now have a means of tracking claims data for spiritual care services offered as a plan benefit,” Christiansen told Hospice News in an email. “Tracking the use and services of chaplains is an important and overlooked data. Our hope is that institutions that use these codes will allow for data collection.”

Previously, coding methodologies included chaplain interactions in 15-minute increments and were not included on Medicare claim forms, making those professionals the only interdisciplinary team members whose full range of services were not reported.

In recent years, the hospice community has sought better ways to measure and account for chaplain services.

For instance, four hospice advocacy groups early last year wrote to CMS Administrator Chiquita Brooks-LaSure to request the expanded codes.The signatories included the National Association for Home Care & Hospice (NAHC), the National Hospice and Palliative Care Organization (NHPCO), the National Partnership for Healthcare and Hospice Innovation (NPHI) and LeadingAge.

This broader scope of documentation can help demonstrate a need to better support the full range of care delivery, according to Dr. Amy Moss, senior vice president of clinical hospice operations at Amedisys (NASDAQ: AMED).

“Demonstrating the use and scope of this role brings forth an opportunity to further educate the public of the many services our highly trained spiritual care team offers and validates the important work they are doing,” Moss told Hospice News in an email. “This validation will also assist in bringing top talent into these roles.”

The three HCPCS codes were initially rolled out for the VA in 2019 after previous spiritual care billing codes were discontinued in 2014.

Without those codes, it had become difficult for VA facilities to hire chaplains. VA facilities could no longer include chaplains in their clinical count, and the agency’s funds were insufficient to keep them in the administrative count, according to Saul Ebema, president of Illinois-based Hospice Chaplaincy.

“These codes gave more access to spiritual care for VA patients and provided employment opportunities for chaplains within the VA system,” Ebema told Hospice News in an email. “I see value in having a standardized code for all the spiritual care that is provided in all settings.”

Some stakeholders hope that wider utilization of the codes across the health care system will allow for better data collection to examine chaplains’ impact on patient and family outcomes, according to Ebema.

A key factor in the CMS decision was the addition of chaplain services as a supplemental benefit within Medicare Advantage, which demonstrated a need to expand coding beyond the VA.

“Individual insurers have the necessary flexibility to assign codes from within the Level II HCPCS code set to report items and services on electronic claims if they deem appropriate, consistent with their programs and policies,” CMS stated in the email. “In each case, the text revision eliminated specificity to the VA, giving other (e.g. non-VA) insurers the flexibility to assign [the codes] for reporting to them on electronic claims, if they so choose.”

Though many stakeholders have welcomed the changes, some chaplains have indicated that confusion persists as to how providers should use them outside of the VA setting, including hospices. Complicating the matter is the bundled nature of the hospice per-diem payment model.

CMS has directed providers to work directly with payers to sort out the specifics on how to use the codes.

“Inquiries regarding whether and under what circumstances a particular item or service would be covered and paid, and regarding any associated compliance, documentation and reporting requirements, should be submitted directly to the insurer(s) in whose jurisdiction(s) claim(s) would be filed,” according to CMS.

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