Dr. Saul Ebema
On July 7th, 2021, the Department of Health & Human Services and the Centers for Medicare & Medicaid Services held a meeting to discuss many issues including Healthcare Common Procedure Coding System (HCPCS).
Of significant interest to us at Hospice Chaplaincy was agenda item #8 and number 21.023 which was submitted by HealthCare Chaplaincy Network requesting CMS to adopt the current code for spiritual care used by Veteran Health Administration to be used for Hospice and Palliative care chaplain visits.
The request involved removing the existing language from three VA chaplain visit codes to make it applicable to hospice and palliative care chaplains.
1. Existing language: HCPCS Level II code Q4251 “Assessment by Department of Veterans Affairs chaplain services.”
Change wanted by HealthCare Chaplaincy Network: Applicant’s suggested language: HCPCS Level II code “Assessment by chaplain services.”
2. Existing language: HCPCS Level II code Q4252 “Counseling, individual, by Department of Veterans Affairs chaplain services.”
Change wanted by HealthCare Chaplaincy Network: : Applicant’s suggested language: “Counseling, individual by chaplain services.
3. Existing language: HCPCS Level II code Q4253 “Counseling, group, by Department of Veterans Affairs chaplain services.”
Change wanted by HealthCare Chaplaincy Network: : Applicant’s suggested language: “Counseling, group by chaplain services.”
Historical Background of the VA Chaplain visit Code
VA chaplains used Code 999499 CPT from the 1990s to 2014. This unspecified code was never billable, but it made chaplains part of the clinical count, nonbillable workload within the VA’s VERA (Veterans Equitable Resource Allocation) system.
Then in 2014 this code was taken away and chaplains became administrative overhead – this was a huge setback for VA Chaplains. With chaplains being viewed as administrative overhead and not part of the clinical count, nonbillable workload, it negatively impacted the desire of facilities to hire chaplain staff.
In 2019 while serving a 2-year term as National Director of VA Chaplain Service for the Department of Veterans Affairs, Chaplain Juliana Lesher sought support from VA Senior Leadership for the HCPCS (Healthcare Common Procedure Coding System) Code request from CMS. CMS eventually approved. I applaud the work of Chaplain Juliana Lesher on this. It was Such a remarkable achievement in advancing chaplaincy within the VA system.
Approved Codes by CMS for chaplain visits in the VA
Below were the codes approved by CMS for VA chaplains to help them remain under the clinical count as nonbillable workload.
- Q9001 – For spiritual assessment by Department of Veterans Affairs chaplain services.
- Q9002 – For individual chaplain counseling by Department of Veterans Affairs chaplain services.
- Q9003 – For chaplain-led groups by Department of Veterans Affairs chaplain services.
It’s important to note that these codes are non-billable but allow VA chaplains to be part of the clinical count, nonbillable workload for VA. This is important because of the Veterans Equitable Resource Allocation. These codes became effective on October 1, 2020.
Should these codes be translated for Hospice Chaplain visits?
In January 2016, CMS approved a code for Hospice Chaplain visits. Code: G9473 for services performed by a chaplain in the hospice setting, each 15 minutes. This is also a non-billable code.
Are the VA codes more valuable than the current hospice chaplain visit code G9473? They are both non-billable. The VA codes, however, help to keep chaplains within the VA system as clinical staff instead of administrative. But in hospice, chaplains are already part of the clinical staff.
There seems to be a belief within chaplaincy circles that a change of code could make hospice chaplain visits billable but that is not the case because hospice in the United States is reimbursed on a per diem basis, regardless of the services being provided or the disciplines providing those services.
My hope is that we can use the current HCPCS code (G9473) already established for hospice chaplain visits to allow hospice chaplains to report visits on the hospice claim form. But what difference would that even make? Your guess is as good as mine.