Approval of HCPCS Codes for Chaplains

The Centers for Medicare and Medicaid (CMS), a division of the US Department of Health and Human Services (HHS), has for the first time, approved codes for chaplaincy and spiritual care.

What are codes?

Most chaplains working in health care are likely familiar with health care codes as the way their institution gets reimbursed for the care they provide to patients. To bill for care, the intuition generally must be able to claim that it is covered by one of more CMS codes as described in the Healthcare Common Procedure Coding System (HCPCS). a collection of standardized codes that represent medical procedures, supplies, products and services The codes are used, not only to bill Medicare and Medicaid services to CMS but to bill most other medical payers as well,

What may be new to many chaplains is there are two levels of HCPCS codes. Level 1 codes, often called Current Procedural Terminology (CPT) codes, is the one  chaplains are generally familiar with because they are generally used to bill for most clinical services in health care such as surgeries, diagnostic tests, evaluation and management services. The codes consist of five numbers and were originally developed by the American Medical Association (AMA). Level II  HCPCS  codes is used primarily to identify products, devices, supplies, and services. The codes start with a letter followed by four numbers. Importantly for chaplains, not all Level II codes are billable codes. That is, they cannot be used to request reimbursement for the produce or service covered by the code. They are most often used for quality improvement and as a source of research data.

How did the chaplain codes come to be?

Until recently chaplains and spiritual care have not been included in this system. There has been no standard way to measure what chaplains do and how well they do it.  Several years ago, chaplains from the U.S. Department of Veterans Affairs (VA) mounted a successful effort that resulted in three codes for recording the work of health care chaplains — but only in the VA. Those codes were

  • Q9001 Assessment by Department of VA Chaplain Services
  • Q9002 Counseling, Individual, by Department of VA Chaplain Services
  • Q9003 Counseling, Group, by Department of VA Chaplain Services

Almost two years ago, HealthCare Chaplaincy Network began an effort to have CMS allow those codes to apply to all chaplains in health care. In applying for these codes, the most likely way to have them accepted was to use the VA wording but without the reference to the VA. After several rejections, CMS has approved this change in the codes. For the full CMS report on the proceedings that led to this adoption see p. 167 and following of published. The new codes are the same as the original but with “Department of VA” removed.

Thanks are due to those who helped move this effort forward. The HCCN team represented by George Handzo; Chaplains Juliana Lesher and David Goldstrom who led the initial effort at the VA; and our colleagues at Ascension, the National Hospice and Palliative Organization (NHPCO), the National Association of Home Care and Hospice (NACH) and the Association of Professional Chaplains (APC) who all submitted comments in support of the codes. 

Why are these codes important for chaplains?

A famous saying in health care is “If it’s not in the chart, it didn’t happen.” A variant of that is “If you can’t or don’t measure it, it didn’t happen.” For many years, professional health care chaplains have been recognized as the spiritual care leads on the health care team responsible for assessing and meeting the spiritual, religious and existential needs of the patients, loved ones and staff. Despite this recognition, the integration of spiritual care and chaplaincy care has lagged. One of the major reasons for this lag in full integration has been a lack of standardized measures that would allow us to determine what chaplains do, how much of it they do, and what impact it has on health care outcomes. One of the ways this measuring is done nationally is through HCPCS. These codes will also allow the measurement of the chaplaincy contribution to newer health care drivers such as accountable care and health equity. By having them in an institutional EMR, multiple correlations will be able to,be done to establish the relationship between chaplaincy visits, assessments and outcomes including length of stay, site of death, and patient satisfaction scores.  There is much work to do on how to implement these measures. However, there is no question that this is a huge step for professional chaplaincy.  HCCN plans to fully support the ongoing promotion and training necessary to maximize the potential.

Next Steps

At this point, we do not expect any further guidance from CMS on how these codes should be implemented. We also do not expect that these will become billable codes, certainly not in the near term.

It is critical to standardize the implementation and use of these codes across the U.S. so that they can yield maximum benefit for budgeting and quality improvement.

Seems like the next step for all of us is to get these into our system’s EMRs. Do not alter the wording of the codes in any way. The goal is to get some uniform data within and across systems and to be able to run correlations with other data points such as who is being served, what interventions are being done and what the outcomes for these patients are. We also need the EMR stood up before we commence any actual training for chaplains which will come next.

The barrier we expect is institutions not seeing any ROI for them. This is admittedly something of a Catch-22 in that we need the data to show them outcomes, but we do not have the data until this gets into the chart. If that happens, we would recommend showing them work like the patient sat studies done at Mount Sinal NY by Deborah Marin and colleagues and some of the Balbonis’ work that documents the correlation between meeting spiritual needs and use of hospice.

We would value being kept up to date on your progress in this regard especially if you are meeting resistance. Questions and comments should go to George Handzo at

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