By Phil Rodgers, MD FAAHPM
AAHPM Public Policy Committee Co-chair and RUC Advisor

Dr. Jennifer Brokaw’s article from Time magazine linked in the 11/10 SmartBrief concludes that CMS payment for advance care planning (ACP) services, that will start January 1, 2016, is inadequate to support the time necessary for physicians and qualified providers to provide advance care planning services. The article reaches this conclusion by citing that reimbursement amounts are limited to ‘initial’ palliative care consultation and ‘follow-up’ consultations, and thus do not allow payment for longer, more involved ACP and goals of care discussions.

Dr. Brokaw’s attention to the topic is very welcome, but her article may leave readers confused as to the use and value of the new CPT codes for advance care planning. Specifically, the new Current Procedural Terminology (CPT) codes would allow payment for ACP services of any length, including the long, complex discussions that are a practice staple of hospice and palliative care providers. 99497 (~$86) can be billed for the first 30 minutes of ACP services on a given day, and 99498 (~$75) can be billed for each additional 30 minutes of service performed on the same day, with no limit. There are no frequency limitations to these codes, so they may be used as often as the need arises.

They may be also be used in addition to most other inpatient and outpatient evaluation and management (E/M) codes, provided that the time counted to bill the ACP codes is only counted for ACP services, and not also used to meet time-based criteria for an E/M code. There are a few E/M codes (like those for some critical care services) alongside which the new ACP codes cannot be billed—so do read the fine print, preferably with your practice’s billing professional or consultant.

It is important to note that while CMS issued no specific documentation requirements for use of the new ACP CPT codes, they will be subject to audit. In fact, Medicare contractors may be watching a little more closely given that these codes are new, and there is an interest in making sure they are billed only when the services are delivered. As always, make sure you are documenting (in detail) the services that you perform.

I do agree with Dr. Brokaw that the new Advance Care Planning CPT codes are not a solution to better payment for advance care planning and palliative care services. They are, however, an important step in the right direction. In fact, AAHPM worked with other medical specialty societies to advance the new CPT codes for advance care planning, including presenting data from member surveys to the American Medical Association/Specialty Society Relative Value Scale Update Committee (RUC) which suggested relative values for the codes to CMS.

For more information, please review the CMS fact sheet and full text of 2016 Medicare Physician Fee Schedule Final Rule.”