Advance Care Planning Billing

It is common for hospitalists to have advance care planning discussions and address advance directives with patients (and families) during an admission for a serious life-threatening condition or end-stage chronic disease.

Medicare waives the coinsurance and the Medicare Part B deductible for ACP when:

● Provided on the same day as a covered AWV

● Furnished by the same provider as a covered AWV

● Billed with modifier –33 (Preventive Services)

Voluntary ACP is considered a preventive service when billed with the AWV on the same day by the same provider, so CMS waives the deductible and coinsurance for ACP. When AWV is medically necessary and billed with ACP, but the AWV is denied for exceeding the once-per-year limit, payment can still be made for the ACP. In that case, CMS applies the deductible and coinsurance to the ACP service.

The deductible and coinsurance DOES apply when ACP is provided outside the covered AWV.

NOTE: Critical Access Hospitals (CAHs) may bill for ACP using type of bill 85X with revenue codes 96X, 97X, and 98X. The CAH Method II payment is based on the lesser of the actual charge or the facility-specific Medicare PFS.

Total time spent specifically on advance care planning must be face-to-face with the patient, family, and/or surrogates, and it must be documented in the record. Although Medicare contractors may have more specific documentation requirements, Medicare identifies certain elements typically expected including time spent, the voluntary nature of the services and patient consent, an account of the discussion, an indication that advance directives were explained, and who was present.