Hospice, Palliative Care Groups Call for Telehealth Codes on Medicare Claims

A coalition of hospice and palliative care industry groups has urged lawmakers to make billing codes for telehealth available on Medicare hospice claim forms.

The organizations called on Congress to require the U.S. Centers for Medicare & Medicaid Services (CMS) to develop and implement Healthcare Common Procedure Coding System (HCPCS) codes or modifiers for telehealth visits. 

The coalition made their request in a letter to leaders of key congressional committees, Ways and Means in the House and Finance in the Senate.


“Because CMS does not require the collection of data on the use of telehealth through the hospice claim form, no consistent information on the use of telehealth, and its impact on patient access and quality, is being gathered,” the groups indicated in the letter. “Hospice providers need the opportunity to reflect the full scope of care provided to patients experiencing serious illness.”

Signatories included the National Hospice and Palliative Care Organization (NHPCO), Hospice Action Network (HAN), the National Association for Home Care & Hospice (NAHC), the Center to Advance Palliative Care (CAPC), the American Academy of Hospice and Palliative Medicine, LeadingAge, and close to a dozen others.

Telehealth has boomed due to a series of 1135 waivers that CMS implemented during the COVID-19 public health emergency (PHE) and provisions in the CARES Act. While these flexibilities are temporary and are set to expire five months after the PHE ends, many providers contend that telehealth has become an integral component of care delivery.


Without billing codes, providers have no way to measure telehealth services, meaning that many of these visits are not documented in any official record, the industry groups argued in the letter. Thus, patients’ records do not reflect the full scope of care they receive, and hospice organizations lack a methodology for capturing the quantity or quality of telehealth visits.

This request dovetails with previous recommendations by the Medicare Payment Advisory Commission (MedPAC) to include telehealth visits on hospice Medicare claims. The commission indicated that a lack of telehealth utilization data during the pandemic has made it difficult to accurately predict costs for coming years.

“As your committees have uncovered, one small unforeseen benefit of the COVID-19 pandemic has been the rapid development of telehealth technologies and practices which help patients access care more easily, without sacrificing quality,” the letter said. “We believe that this will be borne out by the data; and believe that collecting accurate information is critical to drafting long-term policy, and effective guardrails, around the use of telehealth in the future.”

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