San Francisco HSS approves testimony backing CMS reimbursement codes for advanced care planning

The Health Services Board for the City and County of San Francisco voted to approve testimony to the Centers for Medicare & Medicaid Services asking that two CPT reimbursement codes be adopted for advanced care planning counseling. The board approved the testimony by voice vote after a presentation from Director Catherine Dodd.

Director Catherine Dodd told commissioners that creating billing codes for time spent counseling patients about end-of-life preferences would let the system measure whether vendors and providers document advance directives in electronic health records and would enable better performance guarantees. "Giving this a billing code will allow us to measure our vendors in terms of how well they're doing, in having this important information in medical records," Dodd said.

The board's testimony urges CMS to allow reimbursement when counseling is provided individually (not in group settings), to include nurse practitioners, physician assistants, nurses and social workers as eligible providers where appropriate, and to require training for clinicians conducting the counseling. Commissioners discussed the relationship between counseling and palliative care; Dodd and Commissioner Dr. Steven Elliot Follansbee clarified that the proposal covers counseling and advance-directive documentation, not palliative-care reimbursement per se.

Members of the public urged clarity about how and when to update advance directives. Claire Zavonsky, a retired employees' representative, asked for language the board could publish for members; Dodd pointed to guidance in the meeting binder and suggested using annual open-enrollment seasons as a prompt for review.

Commissioner Breslin moved to approve the testimony and the motion carried by voice vote. The board directed staff to transmit the approved testimony to CMS as the next procedural step.