March 6, 2024 | Nichole Soderquist, Sue Belley
As we embark on a new calendar year (CY), there are several new updates and guidelines we should examine that went into effect Jan. 1, 2024. Specifically, improvement efforts surrounding quality of care continue to be of focus, as seen through the development of new CPT® and HCPCS Level II codes as well as expanded coverage of services.
The quality of care in health care can significantly impact patient outcomes, satisfaction and overall system effectiveness. High quality care ensures accurate diagnoses, appropriate treatments and improved overall health outcomes for patients. Conversely, poor quality of care may lead to adverse effects, increased health care costs and decreased patient satisfaction. Continuous efforts to improve and measure the quality of care are essential for a robust health care system.
For CY 2024, the Centers for Medicare & Medicaid Services (CMS) finalized its proposal to allow payment when practitioners train caregivers to support patients with certain diseases or illnesses carrying out a treatment plan. CMS will pay for these services when furnished by a physician or a non-physician practitioner. A non-physician practitioner may be identified as a nurse practitioner, clinical nurse specialist, certified nurse-midwife, physician assistant, clinical psychologist, physical therapist, occupational therapist or speech language pathologist. The new update to support caregivers and increase access to high quality of care is consistent with the recent Biden-Harris administration executive order. Three new CPT codes were developed and published by the American Medical Association to capture caregiver training services:
CHI services focus on addressing the particular social determinants of health (SDoH) needs that interfere with, or present a barrier to, diagnosis or treatment of the patient's problems addressed in the CHI initiating visit. CHI services can be performed by certified or trained auxiliary personnel, which may include community health workers or others who are external to, and under contract with, the practitioner or the practitioner's practice, such as through a community-based organization. Two new codes were developed by CMS:
CMS finalized four new time-based codes for PIN services which can be furnished following an initiating evaluation and management (E/M) visit which addresses a serious high risk condition/illness/disease expected to last longer than three months, such as cancer, chronic obstructive pulmonary disease, congestive heart failure, dementia, HIV/AIDS, severe mental illness and substance use disorder. PIN services are incident-to services, therefore, they may only be performed in a non-facility setting. Time spent performing the services must be documented in the medical record, and the work done must be documented in the medical record.
There are several activities that must be incorporated in the CHI and PIN services rendered. In addition, written or verbal patient consent is required in advance of providing PIN and CHI services. This new regulation was not initially in the physician fee schedule proposed rule. With the implementation of new service coverage and development of CPT/HCPCS level II codes, the improved access to services is predicted to result in a reduction of health care disparities for Medicare beneficiaries in underserved populations.
For a deeper dive into 2024 updates to OPPS and CPT codes, check out our Quality Webinar page and visit the recording of our January webinar.
Sue Belley, RHIA, is senior manager, compliance and audit services at 3M Health Information Systems.
Nichole Soderquist, MBA, RHIA, CDIP, CCDS-O, CCS, is ambulatory services consulting manager, consulting services at 3M Health Information Systems.