What HCPCS Codes Mean for Chaplains

Since April of 2014 APC along with other chaplaincy groups have sought to add or extend codes for chaplaincy related services to one of the major healthcare coding systems in the U.S. including CPT and HCPCS codes.  In 2016 APC led an unsuccessful effort to petition the AMA to add a CPT code specifically for chaplains.  In 2021 APC worked with HCCN’s Rev. George Handzo BCC, to amend three new Q-codes that were specifically created at the request of the Department of Veterans Affairs for VA Chaplains. The goal was to remove the VA qualifier from the HCPCS codes so that they could be utilized by all chaplains in the healthcare space for their services. In October 2022 CMS announced that they were removing the VA language, and these Q-Codes could now be used by chaplains working outside of the VA.

New Codes for Chaplain Services

Removing the “department of veterans affairs” qualifier means that the Centers for Medicare Services (CMS) has approved three HCPCS Level II procedure codes for all chaplain services.  These codes are:

Q9001 – Assessment by chaplain services
Q9002 – Counseling, individual, by chaplain services
Q9003 – Counseling, group, by chaplain services

These codes are in addition to the long established G9473 which is used for chaplain visits in the hospice setting.

The approval of these revised codes will give CMS and other insurance providers a standard way to process claims reporting for chaplain activity now and as new quality measures are put in place. Insurers will now have a means of tracking claims data for spiritual care services offered as a plan benefit. The “Q” codes will give chaplains the ability to note their contributions to patients’ overall care through spiritual assessments, individual spiritual counseling, and group spiritual counseling.  CMS has stated that it will be releasing more detailed guidance and definitions for how these codes are to be used soon.  Until we have further guidance from CMS, APC recommends connecting with you chargemaster department to make them aware of the new HCPCS codes for chaplain’s services.

The new “Q” codes will not provide additional revenue for a care facility at present.  They do move chaplains into a better position by providing more equal footing with professionals in the healthcare setting.  The question around future revenue from chaplain visits is still open and is related to the payment models currently in use by CMS and other insurance providers. 

Most Common Payment Models

The most common payment model is based on DRG’s.  DRG stands for Diagnostic Related Group.  This is the model CMS uses for Medicare, Medicaid payments.  Many insurance carriers also use a DRG model.    There is a DRG code for a given diagnosis, complexity of the diagnosis with some additional modifiers.  For example, there are three DRG’s for gallbladder, DRG 444, 445 and 446, based on complexity of the case.  In the DRG model, the hospital gets a set payment based on the DRG.  All care, medication, therapy and services are covered by the single DRG payment.  Physician services are typically a separate entity and do bill separately with some exceptions. In this payment model, the only way chaplains (and all care providers) can impact revenue is by demonstrating the care meets the requirements of a more complex DRG for a given diagnosis.

The second most common model is a fee for service.  The hospital or system has a negotiated payment rate based on the services provided.   Most typically this is based on the bill with discounts and modifiers.  For chaplains, an insurance providers would have to agree the hospital can bill for the services and determine a payment rate.

About the Coding System

HCPCS stands for “Healthcare Common Procedure Coding System”.  HCPCS is a collection of standardized codes that represent medical procedures, supplies, products, and services. The codes are used to facilitate the processing of health insurance claims by Medicare and other insurers. The coding system is divided into Level I and level II.  

Level I codes, which are commonly referred to as CPT codes, provide a descriptive list of medical services and procedures with a code to identify for billing purposes.  For example, a cardiac bypass graft is 92944.  Level II HCPCS codes identify products, supplies, and services not included in CPT.

Level II codes consist of a letter followed by four numeric digits.  HCPCS codes may or may not be billable.  It should be noted that the three approved codes are Q9001, Q9002, Q9003.  “Q” codes are considered temporary codes by CMS.  “Q” codes can remain indefinitely but are often transitioned to another letter as a permanent designation or they can be eliminated at some future date.  The current hospice chaplain code, G9473, is also temporary code and has been used since 2016.

CMS has already stated that it will provide code users with updates as to how best to implement these codes soon.  Until we have additional guidance from CMS, APC is encouraging professional chaplains to share the updates to the Q9001-9003 and the G9473 codes with their chargemaster and other relevant personnel within their organizations.  We will share any new information that we receive as soon as we can.  If you have information or feedback regarding these codes, we welcome you to send your comments to info@apchaplains.org.