Change Request (CR) 9369 was released by CMS on Friday, October 16, 2015, providing Additional G-Codes that will differentiate Registered Nurses (RNs) and Licensed Practical Nurses (LPNs) in Home Health and Hospice claims. We were made aware that this would be necessary beginning with hospice services provided on or after January 1, 2016. The two codes, G0299 for RNs and G0300 for LPNs, will allow the Medicare MACs to appropriately pay hospices for RN visits during the last seven (7) days of life in the Routine Home Care (RHC) setting when those visits are eligible for the Service-Intensity Add-on (SIA).

These two G-codes will be applicable effective for hospice dates of services on and after January 1, 2016 (January 2016 claims), and for home health episodes of care ENDING on or after January 1, 2016. The new G codes will need to be reflected on all LPN or RN visits that have a date of service January 1, 2016 and later. With the implementation of the use of the new codes the existing “G0154 — Direct skilled nursing services of a licensed nurse (LPN or RN) in the home health or hospice setting” will be retired.

CR 9369 modifies the Medicare Claims Processing Manual for both home health and hospice to require use of the two new G-codes (with retirement of G-0154). It also corrects the existing example for the two-tiered RHC payment system as the example as previously issued in the hospice chapter. It was incorrect relative to the day counts (it did not take into consideration that 2016 is a leap year). CR9369 also provides additional claims submission detail over the example for the SIA provided in CR 9201 to reflect the newly-established G-codes. Use of the new G-codes will be required for both home health and hospice under Medicare and may be applicable to Medicaid and other payer claims where reporting of nursing visits is required.

The shock with all this is that it has been made applicable to home health with no warning prior to the issuance of this CR. Some software systems are not currently prepared to handle this change, especially with home health, while other systems are easily adaptable due to having effective dates for the codes and the system administrator will just need to add the new codes with the appropriate effective date and give a termination/expiration date to G0154.

The key to success with this code is education of staff that will be selecting the appropriate code. The elephant in the room is that G0164 – – Teaching & Training, which is also used by both a RN or LPN will remain as G0164 so when it should be used for a home health patient there will be no differentiation between RN or LPN.