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Procedure/Diagnosis Coding and Reimbursement Mechanisms for Physician Services in Palliative Care

EPEC Trainer's Guide 1999

Charles von Gunten, MD, PhD, Frank Ferris, MD



The objectives of this section are to:

  • understand how to code for physician services related to palliative care, including hospice

  • understand the difference between the reimbursement mechanisms to be used when the patient is enrolled in the Medicare hospice benefit and the usual reimbursement mechanisms

Physicians can code and bill for services related to palliative care by using existing mechanisms. This section first discusses coding for physician services by standard coding approaches. Then it presents how those same approaches need to be adapted when a patient has elected the Medicare hospice benefit. Finally, it describes how palliative care services other than physician services are paid.

Coding for physician services related to palliative care

Coding for physician services, whether the patient is enrolled under the Medicare hospice benefit or receives healthcare services through other funding mechanisms, almost always uses the same coding technique. Physicians code for their service to an individual patient in two parts: 1) a procedure or service code and 2) a diagnosis code.

1) Procedure or service codes

The physician selects a procedure code from the Current Procedural Terminology (CPT)TM codes published by the American Medical Association. For physicians involved in palliative care, the most frequently used codes are the evaluation and management (E/M) codes (code range, 99201-99499). There are evaluation and management codes for each of the usual settings in which physicians provide services: ambulatory outpatient, acute inpatient hospital, extended care institutions or patients' homes. Within each general category of codes (by setting) there is a hierarchy of codes from least intensive to most complex.

The Health Care Financing Administration (HCFA) has promoted extensive guidelines for the documentation that must support the use of each of the E/M codes. Related to palliative care, a little-known and underappreciated provision of current E/M coding guidelines often applies. When more than 50% of the patient-physician interaction is composed of counseling and/or information giving, then time becomes the factor that determines the level of service that is coded. As palliative care consultations and services often incorporate extensive amounts of information giving and/or counseling as part of the physician-patient interaction, then the time it takes to complete the activity determines which E/M code will be chosen. Each of the E/M codes is associated with a time element for this purpose. Table 1 indicates current codes with an amount of time associated with each.

When time is used to determine which E/M code to use, the documentation must indicate that more than 50% of the interaction was related to counseling or information giving. In the inpatient setting, the time is defined as floor or unit time, which includes the time that the physician is present on the patient's hospital unit and at the bedside rendering services for that patient. This includes time in which the physician establishes and/or reviews the patient's chart, interviews and examines the patient, writes notes, and communicates with other professionals and the patient's family.

Physicians who provide palliative care may also report codes for specific procedures or tests that they may perform (such as anesthetic injections, paracentesis, and thoracentesis). The time required to provide these procedures or tests is not included in the time used to establish the appropriate E/M code.

An example

You are asked to provide palliative care consultation for an 86-year-old former schoolteacher who has been admitted to the hospital for exacerbation of congestive heart failure. The attending physician would like advice on managing her dyspnea. You spend an hour on the unit reviewing the chart and interviewing/examining the patient and an additional 20 minutes writing your note and conferring with the attending physician. The majority (more than 50%) of your interaction with the patient was related to eliciting her values and care goals, clarifying her understanding of her diagnosis and prognosis, and giving information and counseling. You had specific suggestions about the use of morphine to relieve her dyspnea.

You would code 99254 for this initial consultation in the hospital. In the note documenting the consultation, you would indicate the name of the referring physician, the reason for the consultation, the recommendations for medical management of the dyspnea, the fact that the majority of the interaction was related to counseling and information giving, and a summary of the situation and the information around which counseling or information giving was required. The note should indicate that the total time spent on the consultation, including the time spent in documentation and discussing the case with the referring physician, was 80 minutes.

2) Diagnosis codes

Besides CPT code, the physician describes the reason for the service by using one of the International Classification of Disease . Clinical Modification (ICD-9-CM) codes promulgated by the National Center for Health Statistics (NCHS). These diagnosis codes are published by several publishers, including the American Medical Association. The ICD-9-CM book contains not only disease codes but also many symptom codes. A few examples are indicated in Table 2.

Many physicians, particularly internists, are concerned about reimbursement for concurrent care; that is, if they see they a patient on the same day as another internal medicine specialist or subspecialist, only one of them will have their services reimbursed. In October 1995, HCFA published new rules that permit concurrent care by two or more physicians on the same day, even if they are of the same specialty. In order to describe the legitimate differences in evaluation and management services that multiple physicians may provide to a single patient, physicians need to use different ICD-9-CM codes for diagnosis as appropriate.

An Example

For the 86-year-old woman with congestive heart failure described above, if both her general internist and the palliative care specialist use the ICD-9-CM code for congestive heart failure, only one submission for reimbursement is likely to be accepted and the other denied. However, if you are being consulted for advice related to management of shortness of breath, you would use the ICD-9-CM diagnosis code for dyspnea (286.6).

Reimbursement for physician services related to palliative care

Medicare hospice benefit background

The Medicare hospice benefit was established in 1982 to pay for hospice services at home for Medicare beneficiaries. Provision is also made for brief periods of inpatient services. A patient is eligible to elect the Medicare hospice benefit if the patient is confirmed by two physicians to have a prognosis of less than or equal to 6 months if the disease follows its usual course. The patient must acknowledge the terminal nature of the illness and sign election forms that indicate that care will be directed toward comfort, not cure of the disease. When a patient elects the Medicare hospice benefit, care of the patient that is related to the terminal illness is the direct responsibility of the hospice program. The benefit pays 100% for intermittent nursing, social work, chaplain, nurse aide, physical/occupational therapy, medication and therapy related to the terminal illness and durable medical equipment. The hospice agency receives a per diem rate to cover these costs. This rate is set by the federal government and is not influenced by the particular treatments or services that the patient receives. As such, it is an example of capitated medical care. Many commercial payers have adopted similar approaches to covering home hospice care. If a patient needs medical care that is not related to the terminal illness, then that care can be provided and reimbursed by standard Medicare mechanisms. It is the responsibility of the hospice physician to determine whether care is related or unrelated to the terminal illness.

Payment and coding for physician services under the Medical hospice benefit

1) Administrative/supervisory activities

As part of the benefit, the services of the hospice medical directory that relate to the administrative and general supervisory activities of the hospice are included in the per diem. "These activities include participating in the establishment, review, and updating of plans of care, supervising care and services and establishing governing policies" (Medicare Regulations, Section 406). Therefore, the medical director should expect his or her administrative services to be reimbursed from the hospice program in addition to fee-for-service billing for direct patient care.

2) Direct Physician services to Medicare hospice patients

Physician services related to direct patient care under the Medical hospice benefit are not covered as part of the per diem rate. Any physician who provides direct care, whether the hospice medical director or other physicians care for the patient, needs to code for his or her services separately. The price mechanism for reimbursement depends on whether or not the physician is associated with the hospice program either as an employee or as a volunteer.

3) Attending physician, not associated with the hospice

At the time the patient elects the Medicare hospice benefit, the patient indicated who his or her attending physician will be. The attending physician for the patient who is not associated with the hospice continues to code for physician services using CPT and ICD-9-CM in the way described above and submits bills for reimbursement to Medicare under Part B (the federal Medicare program that funds physician services from payments made by beneficiaries). However, for paper claims, the physician must indicate on the HCFA-1500 claim form that he or she is the attending physician and not an employee of the hospice program that is caring for the patient when each claim is submitted. If this statement is not present, the services are likely to be denied. For physicians who submit bills electronically (EMC), an HC modifier must be appended to the CPT code. The fiscal intermediary will then telephone the physician's office for further information. When the carrier calls, the information they need is, "This is a hospice patient; Dr. X is the attending physician and is not employed by the hospice."

4) Attending physician associated with the hospice

If the attending physician is associated with the hospice agency (eg, medical director or hospice physician), as a salaried employee or even as a nonsalaried volunteer, then codes for physician services are submitted to the hospice agency and submitted by the agency to Medicare under Part A (the federal Medicare program that covers institutional and nonphysician services funded by payroll deductions). This is a marked departure from other standard approaches to coding and billing for physician services. The hospice agency will submit these bills and are paid at 100% of the usual and customary fee reimbursed under Medicare Part B schedules. The hospice agency then can pass this reimbursement on to the physician as part of his or her negotiated salary or fee-for-service arrangement.

5) Consulting physicians

Consulting physicians who are asked to see the patient by the attending physician can also submit claims for the services they have provided to patients who have elected the Medicare hospice benefit. However, they must submit their code claims directly to the hospice agency, which in turns submits the claims for reimbursement under Part A. This consultants must have a contract with the hospice agency in order for this to occur.

Payment and coding for physician services outside the Medicare hospice benefit

1) Hospice under Medicaid/public aid

Hospice care is reimbursed by many states for their indigent patients. The Medicaid and public aid budgets are administered by individual states, not the federal government. However most states have adopted HCFA/Medicare guidelines for patients who are receiving hospice care. Consequently, the coding guidelines outlines for the federal Medicare hospice benefit also apply. In state-managed programs, it is important that practitioners become familiar with the rules and regulations in the individual states in which they are practicing.

2) Private insurance

Most commercial payers (ie, health plans, insurance companies) require physicians to code for their services by means of CPT and ICD-9-CM codes. Physicians code and submit their claims for reimbursement regardless of whether a patient is covered by a hospice benefit. Again, specific regulations regarding coding may apply for an individual payer. Information on these rules should be obtained before claims are submitted.

3) Palliative care services for patients under Medicare

Physicians may see patients for purposes of delivering palliative care services when they are still covered under Medicare. Use the coding procedures outlines in the first part of this document and submit them to the Medicare fiscal intermediary in your area in the usual way.

Funding for nonphysicians providing palliative care services

Under the Medicare hospice benefit, the per diem fee covers all services of nonphysician healthcare professionals who provide care to the patient and family. However, patients who are not eligible or appropriate for enrollment under the Medicare hospice benefit may have legitimate needs for interdisciplinary palliative care services. The challenge is how to pay for the nonphysician component of such services. Many healthcare professionals, such as nurse practitioners, clinical nurse specialists, social workers, and chaplains, can access fee-for-service billing for patients not enrolled in the Medicare hospice benefit. In many settings, this has not been explored but is available. More commonly, these services are included as part of a larger program of services. For example, when a patient is hospitalized, the hospital reimbursement rate includes nursing, social work and chaplaincy services.

Table 1

Summary of some cpt evaluation/management codes

Attending/managing physician

New/officeEstablished officeInitial hospitalSubsequent hospital
99201 10 min99211 5 min99221 30 min99231 15 min
99202 20 min99212 10 min99222 50 min99232 25 min
99203 30 min99213 15 min99223 70 min99233 35 min
99204 45 min99214 25 min
99205 50 min

99215 40 min
Nursing home-CNursing home-FHome-newHome-Established
99301 30 min99311 15 min99341 20 min99347 15 min
99302 40 min99312 25 min99342 30 min99348 25 min
99303 50 min99313 35 min99343 45 min99349 40 min
99344 60 min99350 60 min
99345 75

Prolonged service face-to-face office/home Prolonged service face-to-face inpatient
99354 30 min99356 30 min
99355 each subsequent 30 min99357 each subsequent 30 min


A consultation is a type of service provided by a physician whose opinion or advice regarding evaluation and/or management of a specific problem is requested by another physiscian or other appropiate source. A physician consultant may initiate diagnostic and/or therapeutic services. The request and the need for consultation must be documented in the medical record. The opinion and any services ordered or performed must also be documented. A "consultation" initiated by a patient and/or family, and not requested by a physician, should be reported by means of codes for confirmatory consultations or office visits, as appropiate. The follow-up codes should not be used if the consultant assumes responsibility for management of a portion or all of the patient's condition(s).

Office/homeInitial hospitalFollow-up hospitalConfirmatory
99241 15 min99251 20 min99261 10 min99271
99242 30 min99252 40 min99262 20 min99272 Low severity
99243 40 min99253 55 min99263 30 min99273 Moderate severity
99244 60 min99254 80 min99274 Moderate to high
99245 80 min99255 110 min99275 min Moderate to high

Table 2

Some common ICD-9 codes physicians may use in palliative care*

Anorexia783.0Inanition263.9Pain: unspecified780.9
Agitation307.9Mental status change780.9Pain: abdomen789.0
Anxiety300.0Nausea787.02Pain: arm729.5
Confusion298.9Nausea & vomiting787.01Pain: back724.5
Coma780.01Vomiting787.03Pain: bone733.90
Cough786.2Weakness780.7Pain: chest786.50
Debility799.3Weight loss783.2Pain: foot729.50
Dementia298.9Shortness of breath786.09Pain: hip719.45
Dyspnea286.6Unconscious780.09Pain: leg719.45
Depression311  Pain: muscle729.1
Delirium780.09  Pain: sacroiliac724.60
Diarrhea558.9  Pain: throat789.1
Fatigue558.9  Pain: neck723.1

*Refer to the full tabular list of ICD-9-CM codes to ensure coding at the highest degree of accuracy.

EPEC Project, The Robert Wood Johnson Foundation, 1999

The Project to Educate Physicians on End-of-life Care comes from the Institute for Ethics at the American Medical Association. Permission to produce for non-commercial, education purposes with display of copyright and attribution is granted.

Emanuel LL, von Gunten CF, Ferris FD. The Education for Physicians on End-of-life Care (EPEC) curriculum, 1999.

Special thanks to the EPEC Team, the EPEC Advisory Group, and all other contributors.


Related References

1. Von Gunten C, Ferris F, Kirschner C,  Emanuel L.  Coding and Reimbursement Mechanisms for Physician Services in Hospice and Palliative Care.  Palliat Med 2000;(3).  http://www.liebertpub.com/JPM/defaultstatic.asp

2. Skolnick AA. MediCaring Project to Demonstrate, Evaluate Innovative End-of-Life Program for Chronically Ill. JAMA 1998;279:1511.

3. Gundersen L. From the Ground Up: A Look at the Role of Foundations in Health. Ann Intern Med 2000; 132:849.

4.  Dowday MD, Robertson MD, Bander JA. A study of proactive ethics consultation for critically and terminally ill patients with extended lengths of stay. Crit Care Med 1998;26(2):252-259.

5.  Campbell ML, Frank RR. Experience with an end-of-life practice at a university hospital. Crit Care Med 1997;25(1):197-202.

6.  Campbell ML, Field BE. Management of the patient with do not resuscitate status: Compassion and cost containment. Heart & Lung 1991;20(4):345-348.

7.  Francke AL. Evaluative research on palliative support teams: A literature review. Patient Education and Counseling 2000;41:83-91.

8.  Carlson RW, Devish L, Frank RR. Development of a comprehensive supportive care team for the hopelessly ill on a university hospital medical service. JAMA 1988;259(3):378-383.

9.  Lilly CM, Demeo DL, Sonna LA, Haley KJ, Massaro AF, Wallace RF, Cody S. An intensive communication intervention for the critically ill. Am J Med 2000;109:469-475.

PubMed, a service of the National Library of Medicine, provides access to over 11 million citations from MEDLINE and additional life science journals. PubMed includes links to many sites providing full text articles and other related resources.  Visit:  http://www.ncbi.nlm.nih.gov/entrez/query.fcgi?db=PubMed

Additional Resources

Data Collection Tool for Hospital Utilization and Cost Patterns

Financial Planning -Grand Rounds
Lynn Hill Spragens, MBA, offers sound advice on developing the financial plan for your palliative care program in an hour audio presentation.

Creating a Compelling Business Case for Palliative Care: Financial Models
A CAPC Management Training Seminar
July 2001, Oakland, CA
PowerPoint Presentation

The Business of Palliative Medicine: Management Metrics for an Acute-Care Inpatient Unit
American Journal of Hospice & Palliative Care
Volume 18, Number 1
January/February 2001

Other Resources By

Charles von Gunten, MD, PhD

Frank Ferris, MD

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