• Using HCPCS Codes G0019 and G0022 for Community Health Integration (CHI) Services

    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:

    • Person-centered planning
    • Health system navigation assistance
    • Facilitating access to community-based resources
    • Practitioner, home- and community-based care coordination
    • Patient self-advocacy promotion

    Read the CMS Code Descriptors for G0019 and G0022

    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: 

    • Person-centered assessment, performed to better understand the individualized context of the intersection between the SDOH need(s) and the problem(s) addressed in the initiating visit 
      • Conducting a person-centered assessment to understand the patient’s life story, strengths, needs, goals, preferences and desired outcomes, including understanding cultural and linguistic factors and including unmet SDOH needs (that aren’t separately billed) 
      • Facilitating patient-driven goal-setting and establishing an action plan 
      • Providing tailored support to the patient as needed to accomplish the practitioner’s treatment plan 
         
    • Practitioner, home-, and community-based care coordination 
      • Coordinating receipt of needed services from health care practitioners, providers, and facilities and from home- and community-based service providers, social service providers, and caregiver (if applicable) 
      • Communicating with practitioners, home- and community-based service providers, hospitals, and skilled nursing facilities (or other health care facilities) regarding the patient’s psychosocial strengths and needs, functional deficits, goals, preferences, and desired outcomes, including cultural and linguistic factors 
      • Coordination of care transitions between and among health care practitioners and settings, including transitions involving referral to other clinicians; follow-up after an emergency department visit; or follow-up after discharges from hospitals, skilled nursing facilities or other health care facilities 
      • Facilitating access to community-based social services (e.g., housing, utilities, transportation, food assistance) to address the SDOH need(s) 
         
    • Health education – helping the patient contextualize health education provided by the patient’s treatment team with the patient’s individual needs, goals, and preferences, in the context of SDOH need(s), and educating the patient on how to best participate in medical decision-making 

    • Building patient self-advocacy skills, so that the patient can interact with members of the health care team and related community-based services addressing the SDOH need(s), in ways that are more likely to promote personalized and effective diagnosis or treatment

    • Health care access/health system navigation 
      • Helping the patient access health care, including identifying appropriate practitioners or providers for clinical care and helping secure appointments with them
    • 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)

    What are the requirements for CHI services?

    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).  

    Are there specific training requirements for those providing CHI services?

    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.

    Is beneficiary consent required for CHI 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. 

    Are CHI services subject to deductible and coinsurance?

    Yes. CHI services are subject to deductible and coinsurance. Some supplemental insurance plans may cover the patient’s cost-sharing. 

    What are the documentation requirements for CHI services?

    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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    How are CHI services billed?

    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. 

    Do private payers cover CHI services?

    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.

    How are CHI services different from other care management services (e.g., chronic care management [CCM])?

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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.

    Can CHI services and other care management services (e.g., CCM) be billed concurrently?

    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.

    How are CHI and principal illness navigation (PIN) services different?

    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. 

    SDOH and Coding Resources