The new Caregiver Training Service (CTS) codes have been in effect for over 1 month now, and proof is starting to pop up in therapy chart reviews. Has your skilled nursing facility (SNF) had the opportunity to use them yet?
What are the 3 new Current Procedural Terminology (CPT) Codes? Codes and descriptions are from the Physician Fee Schedule (PFS) Final Rule for CY2024.
CPT code 97550, face-to-face with caregiver, without patient present
- Initial 30 minutes
- Caregiver training in strategies and techniques to facilitate the patient’s functional performance in the home or community (e.g., activities of daily living (ADL), instrumental ADLs, transfers, mobility, communication, swallowing, feeding, problem solving, safety practices)
CPT code 97551, face-to-face with caregiver, without patient present
- Each?additional 15 minutes (used only after 97550 is billed for 30 minutes)
CPT code 97552, face-to-face with caregivers representing more than 1 patient, without patient present
- Group caregiver training in strategies and techniques to facilitate the patient’s functional performance in the home or community (e.g., activities of daily living (ADL), instrumental ADLs, transfers, mobility, communication, swallowing, feeding, problem solving, safety practices)
Why Are These Codes Unique?
These CTS codes are the first of their kind for therapy, as they are intended for use without the resident present. Therapy CPT codes currently in use require the resident to be present in order to be billed, and any caregiver training that occurs with the resident is billed under the most appropriate CPT code for the training topic (i.e.: ADL, gait, therapeutic exercise).
Other factors that make these codes unique:
- Codes are defined as face-to-face training with the caregiver
- Center for Medicare & Medicaid Services (CMS) has provided a specific definition for “caregiver” as follows: "an adult family member or other individual who has a significant relationship with, and who provides a broad range of assistance to, an individual with a chronic or other health condition, disability, or functional limitation” and/or “a family member, friend, or neighbor who provides?unpaid assistance?to a person with a chronic illness or disabling condition.”
- Written consent is required from the resident to approve the training in their absence. If the resident is unable to consent, the consent of the resident representative is required.
- All CTS codes are not billed using the typical 15-minute unit structure
- The CTS code-set contains its own “group” code, differing from the 97150 CPT Group Code used for treatments that meet the definition of group therapy
When Would The CTS Codes Be Used?
In the PFS Final Rule for CY 2024, CMS provided a framework for usage of the CTS codes.
- “These codes are for?when the treating practitioner?identifies a need to involve and train one or more caregivers?to assist the patient in carrying out a patient-centered treatment plan.” In other words, when the resident is not able to independently carry out necessary components of the treatment plan and/or discharge plan, and needs assistance.
- “The goals and outcomes of the sessions focus on interventions aimed at improving the patient’s ability to successfully perform ADL’s”……”to facilitate the patient’s functional performance in the home or community.”
- “Caregivers are taught how to facilitate the patient’s ADL's (ambulating, feeding, dressing, personal hygiene, continence, and toileting), transfers, mobility, communication, and problem-solving to reduce the negative impacts of the patient’s diagnosis on the patient’s daily life and assist the patient in carrying out a treatment plan.”
As noted in the CMS language above, the training opportunity for caregivers covers a broad spectrum, and allows an opportunity for physical, occupational and speech therapy to pass on essential information with the goal of improved carryover and health outcomes.
What is the Reimbursement for CTS Codes and How Do These Rates Compare to Other CPT Codes Used by SNF Therapy?
These are the National Rates from the CMS CPT look-up tool for CY2024:
Using the National Rates for CY2024, the non-group Caregiver Training codes (97550 and 97551) average $25 for 15 minutes, falling below the per unit rates for the 97000 timed codes listed below, and significantly below the untimed swallowing therapy code, 92526.
Use the CMS CPT look-up tool to get the exact rates for your location by entering your Medicare Administrative Contractor (MAC).
Real SNF Billing Scenarios
It is important to remember that these codes apply to all settings where Medicare Part B is billed, and usage may be more appropriate in some settings than others.
Here are a few SNF scenarios gathered from recent therapy chart reviews.
- Teaching total hip precautions to a caregiver of a resident who cannot comprehend the restrictions, and is in too much pain for therapist to mobilize for the demonstration. Precautions are taught to the caregiver for carryover upon discharge home. Caregiver was also instructed in the need to adjust seating surface height in the home in preparation for resident discharge. Caregiver was provided with verbal and written instructions, and pictures of do’s and don’ts for hip precautions.
- Instructed caregiver in car transfers for resident who had recent stroke with hemiparesis with goal of discharge home. Caregiver requires demonstration on how to transfer resident from wheelchair to car, including proper set up, management of car door and wheelchair parts. Caregiver would benefit from car training with staff prior to introducing resident to the situation, due to resident high anxiety. Training using therapist in place of resident and verbally instructing caregiver throughout transfer to insure competence and safety prior to caregiver training with resident and caregiver’s car.
- Group caregiver training session for caregivers of 3 separate residents on need for and use of thickened liquids due to history of aspiration. Caregivers will be preparing meals/liquids upon discharge home. Group training to review aspiration precautions, how to prepare modified meals/liquids, review of signs and symptoms for concern. Caregivers received verbal, written and video instruction.
Do these situations meet the Caregiver Training Service code definitions? Not a bad start!
But, But, But What About…..???
So many great questions have been asked since the release of these codes! Here are just a few, along with the shortest answer possible!
- Does Medicare Part B reimburse for these codes? Yes – See above rates
- Do other payors reimburse for them? Depends – Need to check with payor
- Can PTA and OTA (assistants) use these codes? Yes
- Can these codes be used for telehealth? No
- Do we need written consent from the resident? Yes
- What if the resident is unable to consent? Ask responsible party
- Can time educating caregivers in care conferences count? No
- Can you use the individual and group codes in the same day? Yes
- Is a nurse or nurse aide meet the definition of caregiver? No – need to be unpaid
- Can you bill 97550 if under 30 minutes are provided, for example, if the training only lasts 20 minutes? Yes, as long as AMA CPT billing rules are followed (need to pass midpoint in order to bill...>15 minutes)
- Can the minutes be counted on the MDS? Some debate exists. CTS codes came out after last RAI Manual update 10/1/23. Billing codes required resident contact prior to these new codes. Question is “Do these codes meet the therapy mode definitions? ”Section O states: “Record total number of minutes therapy administered to the resident individually…..” Since resident was not present, can minutes be counted? To date, there is no written clarification from CMS. Using the logic that CTS codes came after, and in these scenarios the caregiver is an extension of the resident, which the resident has consented to in writing, these skilled therapy minutes should qualify for recording on the MDS. See current RAI Manual excerpt below and use your best judgement until clarified by CMS.
Family education when the resident is present is counted and must be documented in the resident's record..... Only skilled therapy time (i.e., requires the skills, knowledge and judgement of a qualified therapist and all the requirements for skilled therapy are met) shall be recorded on the MDS.... Therapist time during a portion of a treatment that does not meet the therapy mode definitions may not be included." RAI Manual Ch 3, Page O-24, "Minutes of Therapy"
In Summary
The parameters of the new CTS codes provide a significant opportunity for PT, OT and Speech professionals to share vital information with caregivers on a number of topics (and bill for their time!) that will hopefully result in improved health outcomes for the residents.
It is important to note that CMS built into the code definitions, the verbiage "to facilitate the patient’s functional performance in the home or community.” This does not mean that long-term care (LTC) residents are excluded from CTS training, and the need should be outlined in supporting documentation when provided. There will likely be more instances of caregiver training with the resident present vs without in the LTC setting, and in those instances, we should continue to document and bill as we have been for years, under the corresponding CPT code that covers the topic of training. But it's nice to have options!!
Based on requirements of these new codes, here are a few things to keep in mind:
- Need is individualized. It should not be routine for all residents; therefore, CTS codes should not be in every single plan of care.
- Per CMS, the need for involving a caregiver in training is "identified by the treating practitioner." Therefore, it should be documented on the evaluation or in a later document, outlining why this type of training is required, what the goals are, and why the resident need not be present. (Need is not identified by schedulers, managers or corporate policy.)
As always, if you have any questions about the information or how it will impact you, send them here:?Just Ask Q&A
Dolores Montero, PT, DPT, RAC-CT, RAC-CTA
SNF Therapy & MDS Resource Team
SNF REHAB MANAGER CERTIFICATION PROGRAM
Marketing Specialist at Total Education Solutions
5 个月How do you konw OTA, PTAs can use this code? Is it because PA's are allowed to? Thank you.
ForensicJBCR/OCR Education and Case Management Occupational Therapist QMHP-CS MS in Clinical Rehabilitation Counseling student AOTA Board Certified in Gerontology
8 个月Where did you find that there must be written consent? It is not written in the explanation of the CPT code by AMA nor by billing guidance of CMS. Thank you