Hospice CPT Codes
Hospice services are primarily billed under the Medicare Hospice Benefit rather than through individual CPT codes, but when physicians provide services outside the hospice benefit or for non-hospice patients requiring palliative care, specific CPT codes exist for case management and care plan oversight.
Primary Coding Framework
Case Management Telephone Services
For telephone-based case management and counseling related to hospice and palliative care, use the following CPT codes based on complexity 1:
- CPT 99371: Simple medical decision-making
- CPT 99372: Intermediate medical decision-making
- CPT 99373: Complex medical decision-making
Care Plan Oversight Services
For ongoing management of hospice patients, particularly those receiving care from a hospice agency, nursing facility, or at home, use these cumulative monthly codes 1:
- CPT 99374-99375: Care plan oversight for patients in home health or hospice settings
- CPT 99377-99380: Care plan oversight services (time-based, cumulative over 30 days)
These codes capture physician work in complex, multidisciplinary management and include telephone time as part of broader oversight activities 1.
Important Billing Considerations
Medicare Hospice Benefit Context
When patients are enrolled in the Medicare Hospice Benefit, the reimbursement mechanism differs from usual fee-for-service billing 2. The hospice agency receives a per diem rate that covers most services, and separate physician billing is limited to specific circumstances 3.
Documentation Requirements
To bill these codes, physicians must 1:
- Document the encounter thoroughly
- Specify complexity (for telephone codes) or time spent (for care plan oversight)
- Submit charges on CMS-1500 forms
- Be prepared to collect patient copays if required
Reimbursement Reality
Most government payors and private health plans do not routinely reimburse for telephone care codes (99371-99373), even when properly documented 1. However:
- Some Medicaid managed care plans include telephone triage under capitation
- Certain Medicare plans pay for care plan organization/review calls
- Private insurers vary widely (one study showed 14 of 18 insurers reimbursed at 26% of charges) 1
Common Pitfalls
Misunderstanding the hospice benefit structure: Physicians often don't realize that once a patient enrolls in Medicare Hospice, most services are bundled into the hospice per diem payment 2
Inadequate documentation: Failing to document complexity or time spent will result in claim denials
Billing for services already covered: Attempting to bill separately for services included in the hospice per diem
Not verifying payer policies: Assuming all insurers follow the same rules for hospice-related billing
Practical Algorithm
For patients enrolled in Medicare Hospice Benefit:
- Bill through the hospice agency's per diem (most services)
- Use care plan oversight codes only for allowable separate physician services
For patients receiving palliative care but NOT in hospice:
- Use case management codes (99371-99373) for telephone encounters
- Use care plan oversight codes (99374-99380) for ongoing complex management
- Verify individual payer policies before billing
For all hospice/palliative care billing:
- Document meticulously (complexity, time, medical decision-making)
- Understand that reimbursement rates are typically lower than standard E/M codes
- Consider time-based billing codes when appropriate to capture extensive counseling work 4