Q&A: Initiating CHI services

Wednesday, April 10, 2024

Q: When is it appropriate to initiate community health integration (CHI) services?

A: Providers can initiate CHI following an annual wellness visit (AWV) and certain evaluation and management (E/M) visits, including the E/M visit that is part of a transitional care management (TCM) service (Current Procedural Terminology [CPT®] codes 99495–99496). Providers can bill the initiating E/M, TCM, or AWV visit when their documentation supports a separate service. Practices will only need to perform one initiating visit. An initiating E/M visit every month is not required to bill CHI services, according to the 2024 Medicare Physician Fee Schedule final rule.

However, certain E/M visits can’t initiate CHI, even if the provider can bill E/M visits and identifies unmet social determinants of health during the encounter. A low-level visit that could be performed by clinical staff, such as CPT code 99211 (office or other outpatient visit for the evaluation and management of an established patient that may not require the presence of a physician), is off limits. Observation, inpatient, or emergency department visits are also excluded because the providers involved in these services are typically not following the patient longitudinally in the community or furnishing the CHI services, according to CMS.

Organizations should also have a system for requesting and documenting patient consent before they begin CHI services. The practice or auxiliary personnel can get the patient’s consent verbally or in writing. The process should include letting the patient know that they will have cost-sharing responsibilities and that only one provider can perform and bill CHI during a calendar month. In addition, the practice must get the patient’s consent if there is a change in the provider who is billing the services.

Editor’s note: This answer was excerpted from “Unlock CMS’ 2024 MPFS final rule,” in the January 2024 issue of the NAHRI Journal. The NAHRI Journal is a quarterly journal featuring in-depth analysis and expert advice and is an exclusive benefit of NAHRI membership. Not a member? Join today.