The newly released CY 2024 Payment Policies under the Physician Fee Schedule holds exciting news for therapists and caregivers.  

We have three new codes to be used for reporting the total duration of face-to-face time spent by the physician or other qualified health professional providing individual or group training to caregivers of patients.

This proposed rule marks the first time the Centers for Medicare & Medicaid Services will allow therapists to bill and receive MPFS payment for services without the patient present.

How are the codes defined, you ask?

Caregiver training in strategies and techniques to facilitate the patient’s functional performance (CPT® codes 9X015, 9X016, and 9X017):

  • CPT® codes 9X015 (Caregiver training in strategies and techniques to facilitate the patient’s functional performance in the home or community (e.g., activities of daily living [ADLs], instrumental ADLs [IADLs], transfers, mobility, communication, swallowing, feeding, problem solving, safety practices) (without the patient present), face-to-face; initial 30 minutes), and add-on code), 
  • CPT® code 9X016 (each additional 15 minutes (List separately in addition to code for primary service) (Use 9X016 in conjunction with 9X015)), and 
  • CPT® code 9X017 (Group caregiver training in strategies and techniques to facilitate the patient’s functional performance in the home or community (eg, activities of daily living [ADLs], instrumental ADLs [IADLs], transfers, mobility, communication, swallowing, feeding, problem solving, safety practices) (without the patient present), face-to-face with multiple sets of caregivers) 

Great, how did we get to this point? What is the history, background, and valuation of these codes?

As with all CPT® codes, it’s a process. 

We have our specialty societies in the American Speech-Language-Hearing Association, the American Occupational Therapy Association, and the American Physical Therapy Association to thank for their continued advocacy and excellence in ensuring this code set was appropriately defined.

These specific services are reasonable and necessary when treating practitioners identify a need to involve and train caregivers to assist the patient in carrying out a treatment plan.

The American Medical Association (AMA) CPT® Editorial Panel first approved the codes during its October 2022 meeting followed by recommendations for valuation by American Medical Association/Specialty Society Relative Value Scale Update Committee (RUC). 

The RUC is an expert panel of physicians which makes recommendations to the federal government on the resources required to provide medical services. 

When making recommendations to the federal government, the RUC considers work (including the time and intensity associated with a service), clinical staff time, supplies and equipment, and professional liability insurance associated with performing a service. 

CMS, in the case of these codes, has proposed to accept all RUC recommended values. 

Additionally, the proposed rule notes that three specialty societies sent surveys to a random sample of a subset of their members. The RUC recommended work values based on the survey median values and the key reference CPT® codes 97535 and 97130.

Based upon survey results and after discussion, the RUC recommended a work RVU 1.00 for CPT® code 9X015, a work RVU of 0.54 for 9X016, and a work RVU of 0.23 per specific patient represented. 

The RUC noted that the recommendation for 9X017 is based on a median group size of five caregivers. 

Fantastic, now what are some of the key rules we need to know about these codes? 

While the patient does not attend the training, the goals and outcomes of the sessions focus on interventions aimed at improving the patient’s ability to successfully perform activities of daily living. 

Activities of daily living generally include ambulating, feeding, dressing, personal hygiene, continence, and toileting. 

What are some of the skilled interventions provided during these trainings? 

As with all skilled therapy services, care begins with a comprehensive evaluation.

Therefore, these codes are to be used responsibly as part of an individualized plan of care with the caregiver trained in skills to assist the patient in completing daily life activities. 

These trainings to the caregiver include the development of skills such as safe activity completion, problem solving, environmental adaptation, training in use of equipment or assistive devices, or interventions focusing on motor, process, and communication skills.

During the face-to-face service time, caregivers are taught by the treating practitioner how to facilitate the patient’s activities of daily living, 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. 

In closing, in preparation for CY 2024 the time to review these rules is now. 

Take time to share with your teams, consider how you can integrate into clinical practice and let’s show our highest level of skill in aligning and training caregivers in the coming year and beyond. 

Renee Kinder, MS, CCC-SLP, RAC-CT, is Executive Vice President of Clinical Services for Broad River Rehab. Additionally, she serves as a member of American Speech Language Hearing Association’s (ASHA) Healthcare and Economics Committee, is a member of the University of Kentucky College of Medicine community faculty and is an advisor to the American Medical Association’s Current Procedural Terminology CPT® Editorial Panel. She can be reached at [email protected].

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