Physician Coding, Billing, and Reimbursement
AAHPM believes that physicians practicing Hospice and Palliative Medicine should obtain fair reimbursement for their services and that their valuable skills should become available to more patients. The billing and coding resources below are intended for physicians who provide palliative care services to both hospice and non-hospice patients.
As in all areas of medicine, physicians in palliative care must document the patient care provided and submit billing for that care to the appropriate payer. In both hospice and non-hospice settings, hospice and palliative medicine services are reimbursed using the same billing and coding guidelines that apply throughout the healthcare system. Physician palliative care services are coded for billing using the same CPT (Current Procedural Terminology) codes that physicians use to bill Medicare or other payers for any patient care services they provide.
Unlike traditional coding and documentation, however, many palliative medicine services may best be described by the time spent in counseling and coordinating care. Documenting accurately to support time-based coding can help to ensure appropriate reimbursement.
Palliative care services to non-hospice patients are submitted directly to the payer in the usual manner. Many direct patient care services provided by physicians to hospice patients can be reimbursed separately from the per diem payments made to the hospice agency. The relationship of the physician to the hospice agency often controls to whom the bill is submitted. Hospice medical directors and other physicians employed by or contracted with the hospice agency submit billing directly to the hospice. Under Medicare, these physician service bills are submitted by the hospice to its fiscal intermediary (FI). The FI pays the hospice, and the contract between the physician and the hospice determines how the physician is reimbursed for the care provided.
Disclaimer: Since coding rules and regulations continue to change, and fiscal intermediaries interpret these rules differently, we encourage physicians to refer to several of the resources below as well as other sources, including the CMS Web sites, and collaborate with billing experts. In particular, effective January 1, 2006, there were significant changes to three sets of CPT codes routinely used in palliative care. Specific references to CPT codes in previously-published materials may be out of date.
The Center to Advance Palliative Care (CAPC)
National Hospice and Palliative Care Organization (NHPCO)
The EPEC Project: Education in Palliative and End-of-life Care