- Updates from 2026 Final Rule in this article.
- Marriage and Family Therapists and Mental Health Counselors may personally perform CHI services. They may not supervise auxiliary staff in doing the work, because they don’t have incident to in their statutory benefit, so may not bill for work performed by someone else
- 90791 is added as initiating visit
- These health behavior assessment and intervention services (CPT 96156, 96158, 96159, 96164, 96165, 96167, and 96168) may also serve as initiating visit for providers whe cannot bill E/M codes
- The service is performed by the practitioner who did the initiating visit
This article includes information primarily from the 2024 Physician Fee Schedule Final Rule, but also the 2025 OPPS Fee Schedule in order to address billing when performed at an hospital outpatient department.
The effective date for the CPT® and HCPCS codes, and CMS policy was 1-1-2024.
- Practitioner (physician/NPP) identifies Social Determinants of Health (SDoH) needs that interfere with diagnosis or treatment at an initiating visit
- Monthly services performed by certified or trained auxiliary personnel, such as a community health worker
- The practitioner who does the initiating visit bills for the service
- These services fall under the category of incident to services, requiring general supervision
Two HCPCS codes were created to describe community health integration (CHI) services performed by certified or trained auxiliary personnel under the general supervision of a billing practitioner. The services would require an initiating E/M visit, typically an office visit. CHI is then furnished monthly as medically necessary when the practitioner identifies the presence of SDoH that interfere with diagnosis or treatment.
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