Provider groups and therapists are hailing a new and broader-than-expected opportunity to bill for caregiver training under codes finalized in the 2024 physician fee schedule.
The caregiving training codes were proposed this summer as a vehicle that would allow staff in skilled nursing and other settings to bill for time spent training unpaid caregivers, including family members, once a year.
But in its final rule issued Nov. 2, the Centers for Medicare & Medicaid Services said the codes could be used at the “volume and frequency” needed to meet a physician’s treatment plan, as well as changes in condition or to address new or changed diagnoses, or if there’s a change in caregiver.
Caregivers are “critical members of all of our teams, and it’s really critical that they know how to best support all of their loved ones,” Katy Barnett, director of home care and hospice operations and policy at LeadingAge, said on a policy call with members Monday. “Limiting these codes to just once a year just didn’t make sense and wasn’t efficient to meet patient and caregiver needs.”
LeadingAge had urged CMS to expand the caregiver training services codes, noting that one training per patient annually might not be enough to support robust training for at-home care needs. CMS has explicitly said it was adopting the codes to support because they align with principles outlined in a Biden Executive Order on caregiving issued this spring, and because they more broadly support patient-centered care initiatives.
Caregiver training is described as direct, skilled intervention for the caregivers to provide strategies and techniques to equip them with knowledge and skills to assist patients living with functional deficits, Broad River Rehab Executive Vice President Renee Kinder, RAC-CT, explained in a recent guest column for McKnight’s Long-Term Care News.
Training can be billed in time increments for one-on-one sessions or for group training, if multiple patients have similar conditions or therapeutic needs.
“Skilled training supports a caregiver’s understanding of the patient’s treatment plan, ability to engage in activities with the patient in between treatment sessions, and knowledge of external resources to assist in areas such as activities of daily living (ADLs), transfers, mobility, safety practices, problem solving and communication,” Kinder said.
She encouraged therapists and others working in skilled nursing to learn the rules for use when the codes come into play Jan. 1, implement them to ensure regulatory compliance, and “use this opportunity to increase the quality of care we provide daily.”
For its part, LeadingAge hopes CMS will introduce more flexibility in the codes next year. The organization had used its formal comments to call on CMS to allow physicians to delegate caregiver training to non-billing staff, such as nurses, under the supervision of a clinician and to allow clinical social workers to bill for such training. Barnett said CMS did not clarify whether physicians can delegate the training, but said that CMS would consider making future changes in future rule-making.
Barnett added that LeadingAge also has encouraged CMS to add the codes to its covered telehealth care to “support the majority of caregivers who work full-time or part-time jobs” and might not be in a nursing home or other post-acute setting at the same time as a rounding physician. The finalized rule, however, did not include a telehealth option.
