Starting in 2024, the Centers for Medicare & Medicaid Services (CMS) finalized new Healthcare Common Procedure Coding System (HCPCS) codes to pay for providing CHI services. CHI services provide additional support to patients who have unmet social determinants of health (SDOH) needs that significantly limit the treating physician’s ability to diagnose or treat the patient. CHI services include items such as:
Community health integration services performed by certified or trained auxiliary personnel, including a community health worker, under the direction of a physician or other practitioner; 60 minutes per calendar month, in the following activities to address social determinants of health (SDOH) need(s) that significantly limit the ability to diagnose or treat problem(s) addressed in an initiating visit:
Facilitating behavioral change as necessary for meeting diagnosis and treatment goals, including promoting patient motivation to participate in care and reach person-centered diagnosis or treatment goals
Facilitating and providing social and emotional support to help the patient cope with the problem(s) addressed in the initiating visit, the SDOH need(s), and adjust daily routines to better meet diagnosis and treatment goals
Leveraging lived experience when applicable to provide support, mentorship, or inspiration to meet treatment goals
Community health integration services, each additional 30 minutes per calendar month (List separately in addition to G0019)
Patients must have an initiating visit before receiving CHI services. The initiating visit is where the physician identifies unmet SDOH needs, establishes a treatment plan, and specifies how addressing the unmet SDOH needs would help accomplish the treatment plan. CHI initiating visits include:
Evaluation and management (E/M) visits, including the E/M provided as part of transitional care management
Excludes low-level visits (e.g., 99211) performed by clinical staff
Inpatient and observation visits, emergency department visits, and skilled nursing facility visits would not be considered an initiating visit
Annual wellness visits (when performed by a practitioner who will bill for CHI services)
Subsequent CHI services may be provided by auxiliary staff. CMS expects that CHI services will be performed using a combination of in-person and virtual (via audio-video or via two-way audio).
CHI services are provided incident-to the professional services of a physician or other billing practitioner under general supervision. Auxiliary personnel may be employed by the practice or contracted through an external organization, including through community-based organizations.
Auxiliary staff must meet all incident-to requirements and any state requirements. In states with no applicable requirements, auxiliary staff must be certified and trained in the following competencies:
Patient and family communication
Interpersonal and relationship-building skills
Patient and family capacity building
Service coordination and systems navigation
Patient advocacy, facilitation, individual and community assessment
Professionalism and ethical conduct
Development of an appropriate knowledge base, including of local community-based services.
Yes. Consent may be verbal or written but must be documented in the medical record. Consent should include explaining to the patient that cost-sharing will apply and that CHI services may only be billed by one physician or practitioner per month. Consent only needs to be obtained once unless the treating physician changes.
Yes. CHI services are subject to deductible and coinsurance. Some supplemental insurance plans may cover the patient’s cost-sharing.
In addition to documenting patient consent, documentation should include the unmet social needs the CHI services are addressing, including the treatment plan. CMS encourages practices to document “Z codes,” when applicable. Documentation must include the amount of time spent with the patient and the nature of the activities, including how they relate to the treatment plan. Auxiliary staff does not need to enter information directly into the patient’s medical record; documentation may be entered by other staff as long as the physician reviews and verifies it.
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CHI services are billed monthly and are reported by the physician or practitioner who provided the initiating visit. Only one physician or practitioner may bill CHI services per month.
Most Medicare Advantage plans cover CHI services. For commercial plans, coverage varies by payer. Check with your provider relations representatives for additional information regarding their policies. Verify the patient’s benefits before providing CHI services.
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CHI services are like services such as CCM in that they provide additional, tailored support to patients. CCM services are primarily focused on clinical aspects of care and are limited to patients with two or more chronic conditions. CHI services are intended to address unmet social needs that limit the physician’s ability to diagnose or treat the patient. There are no limitations in the types of patients who are eligible for CHI services.
Yes. As long as the requirements for both services are met, CHI and other care management services may be reported in the same month. Time and effort for both services must be unique – do not count the same time and work more than once.
CHI and PIN services are very similar. A key difference in the services is that CHI services are focused on addressing patients’ unmet social needs. PIN services are focused on helping patients with a serious high-risk condition navigate the health care system and guiding them through their course of care. Patients receiving PIN services may also have unmet social needs, but it is not a requirement.