FAQs
The Centers for Medicare & Medicaid Services (CMS) is responsible for maintaining the codes used to classify medical services and procedures in the United States. In October 2022, CMS approved three Healthcare Common Procedure Coding System (HCPCS) codes that chaplains may use to document patient encounters in the Electronic Medical Record (EMR). These codes are: Q9001 Assessment by chaplain services; Q9002 Counseling, individual, by chaplain services; and Q9003 Counseling, group, by chaplain services.
“Counseling” is the language CMS understands when referring to clinician psychosocial-spiritual interactions with a patient. The first healthcare system to successfully advocate with CMS for chaplain encounter codes was the Veterans Administration. They used the term “counseling” because of the VA’s psychological and therapeutic terminology and reimbursement models. When CMS approved the codes for general use in healthcare systems, they retained the term “counseling” in the code descriptions.
CMS uses the term “chaplain services” to refer to any person designated as a chaplain by the institution. Spiritual Care Association (SCA) recognizes that many institutions provide chaplain services using individuals who are not board-certified chaplains, including CPE students, chaplain interns, and spiritual care volunteers. While it is up to each institution to define a policy for who has access to the chaplain services codes in the EMR, SCA recommends as a best practice that board certified chaplains where available use the codes or supervise their use by non-certified members of chaplain services.
CMS expects a detailed spiritual assessment to be performed when the Q9001 code is used. Assessment includes spiritual, religious, existential (S/R/E) history, identifying S/R/E concerns and resources, the level and nature of spiritual distress, and the impact of S/R/E issues/resources on the patient’s coping, their health status, and their receipt of health services. Recommendations for addressing S/R/E issues in patient care should be included. Several assessment tools have been developed over time and chaplains may favor one over the other. As a best practice, however, SCA recommends that chaplaincy departments strive to use standard, validated instruments in a Q9001 Spiritual Assessment. At this time, only two instruments have been validated by research: Spiritual AIM and PC-7.
The widely used FICA tool (Faith, Importance/Influence, Community, Action/Address) is not an assessment tool for spiritual care specialists but a guide to help other clinical staff take a history of a patient. A tool such as FICA used by a doctor or nurse during patient admission can provide valuable insights for the chaplain on the interdisciplinary team prior to a detailed spiritual assessment being performed. SCA recommends chaplains use a validated in-depth spiritual assessment instrument when using the Q9001 code.
Use code Q9001 only when a full spiritual assessment is performed on the patient during a visit. Use code Q9002 for any other visit with a patient. Use the code for an initial encounter without spiritual assessment or a follow up visit with an established patient, including a bereavement visit. Counseling of others related to the patient can be included if the encounter would normally be included in documentation and the interactions are not separate from the visit with the patient. Documentation and chart review are included in this code and may not be coded separately.
No.
Use this code for an encounter with any established patient in a chaplain-led group discussion including bereavement. Include documentation in the health record of each patient who participates in the group. Documentation and chart review are included in this code and may not be coded separately. Counseling of staff is not included in this code. Documentation must be created in each patient’s health record.
No. Any setting in which the chaplain engages in a session or discussion with more than one patient, formal or informal, counts.
No. These codes can only be used to document patient encounters. SCA recognizes that much of a chaplain’s time is spent in non-patient encounters such as caring for family members, supporting their colleagues, educating on chaplaincy and spiritual care, conducting bereavement groups for loved ones, as well as administrative work on committees and other administrative assignments. The current CMS codes do not account for any of that work. However, the successful use of these codes will help make the case with CMS for additional codes in the future.
No. At the present time these codes are not used to bill for chaplain services. They may eventually become billable.
The codes represent a huge step forward for the profession of chaplaincy. One value of HCPCS codes in the EMR is in the tracking and analysis of health care trends and outcomes. Researchers and policymakers already use this data to improve quality and effectiveness in many clinical and professional arenas of health care. Now for the first time, chaplaincy as a profession has a standardized way to participate in these measures. On the local level, chaplaincy managers will be able to run reports on patient encounters and correlate them with data such as which chaplain performed the encounters, who was the patient, what type of encounter was it, where did it take place, and so on. The chaplain visits can also be correlated with valued outcomes such as patient satisfactions scores, length of stay and whether the patient has an advance directive. These data can be aggregated across healthcare systems to inform research and advocacy for chaplaincy on a national level including advocating with CMS for additional codes and inclusion in bundled payments.
Yes. Although the codes do not count towards billable services, their use will provide useful data for the quality improvement, reporting, advocacy, and analysis on chaplain services performed.
Yes. While some hospices use another HCPCS code that counts services performed by a chaplain, it only applies to the hospice setting. It is important for hospice chaplains to also use the new codes either alongside or instead of the current one so that there is a standard measure for these services across care settings.
Yes, they can be implemented for chaplains working in both inpatient and outpatient palliative care settings.
Yes. The codes can be used by chaplains in any setting that uses an EMR system.
If bereavement support is offered to a patient, you can document this using the Q9002 code. If you are offering support to a group of patients, use code Q9003. You cannot use the codes to document bereavement support offered to family members, loved ones, or clinical staff after a patient dies.
Yes. Every organization has been invited to participate in discussions. This is an industry issue where all organizations need to collaborate on the outcome.
Yes. In late 2023, Epic Systems included the codes in their Foundation System. Typically, these codes will be put into the Charge Capture Navigator section. Chaplains should work with their IT team to determine how their organization plans to implement the codes and where to access them in their Epic system. Many organizations will choose to build these codes into a Preference List for chaplains to select from, but it is up to each organization’s chaplaincy department and IT team to determine whether that is the preferred workflow.
SCA has reached out to the developers of the other major EMR systems. To date, we are only aware of Epic having implemented the codes.