Medicare Coverage for Smoking Cessation Counseling

[Scott Crespy]

News Release

FOR IMMEDIATE RELEASE
Thursday, Dec. 23, 2004

CMS Media Affairs
(202) 690-6145

Medicare Will Help Beneficiaries Quit Smoking

New Proposed Coverage For Counseling as Medicare Shifts Focus to Prevention

HHS Secretary Tommy G. Thompson today announced that the Centers for Medicare & Medicaid Services (CMS) intends to provide new coverage allowing certain Medicare beneficiaries who smoke to receive counseling services that will help them quit the habit.

"We're building on our efforts to help America's seniors help themselves to quit smoking and live longer," Secretary Thompson said. "This new benefit, focused on treating seniors' smoking related diseases, will go a long way toward reducing their risk of dying prematurely. The combination of lives lost, unnecessarily, and the cost of treating smoking-related diseases makes our investment in smoking cessation benefits all that more important. It's never too late to benefit from quitting smoking."

An estimated 9.3 percent of those age 65 and older smoke cigarettes. About 440,000 people die annually from smoking related disease, with 300,000 of those deaths in those 65 and older.

The Centers for Disease Control and Prevention (CDC) estimated in 2002 that 57 percent of smokers age 65 and over reported a desire to quit. Currently, about 10 percent of elderly smokers quit each year, with 1 percent relapsing.

"The evidence available fully supports the hope that seniors at risk of the diseases caused by smoking can quit, given the right assistance," CMS Administrator Mark McClellan, M.D., Ph.D. said. "As we add the 'Welcome to Medicare' exam and other preventive benefits and drug coverage, this is another step in using the medical evidence to turn Medicare into a prevention-oriented program."

The proposal to cover smoking cessation counseling comes in response to a June 2004 request from the Partnership for Prevention (PFP). The PFP requested CMS open a national coverage decision to consider coverage of tobacco cessation counseling as detailed in the HHS Public Health Service (PHS) 2000 Clinical Practice Guideline, Treating Tobacco Use and Dependence.

The guideline has been endorsed by many health care and professional organizations. Based on the evidence reflected in the guideline, CMS proposes to extend smoking cessation coverage to beneficiaries who smoke and have been diagnosed with a smoking related disease or are taking certain drugs whose metabolism is affected by tobacco use. This announcement builds on a series of HHS initiatives designed to help Americans quit smoking, including the opening of a new national quitline (1-800-QUITNOW) and designating all HHS campuses tobacco-free.

While many may think those who quit smoking at age 65 or older fail to reap the health benefits of abstinence from tobacco, the U.S. Surgeon General has reported that the benefits of cessation do extend to quitting at older ages. Smoking cessation in older adults leads to significant risk reduction and other health benefits, even in those who have smoked for years.

The coverage decision involves Medicare beneficiaries who have an illness caused or complicated by smoking, including heart disease, cerebrovascular disease, lung disease, weak bones, blood clots, and cataracts -- the diseases that account for the bulk of Medicare spending today. It also applies to beneficiaries who take any of the many medications whose effectiveness is complicated by smoking -- including insulins and medicines for high blood pressure, seizures, blood clots and depression.

"The best way to prevent the serious health problems caused by tobacco is never to start using it. Millions of our beneficiaries have smoked for many years, and are now experiencing the heart problems, lung problems, and many other often-fatal diseases that smoking can cause. It's really hard to quit, but we are going to do everything we can to help," said Dr. McClellan. "I especially want to urge smokers on Medicare who are just starting to experience heart problems or lung problems or high blood pressure to take advantage of this new help -- and more is coming."

Medicare's upcoming prescription drug benefit will cover smoking cessation treatments that are prescribed by a physician.

CMS Chief Medical Officer Sean Tunis, M.D., said, "Federal policy has acknowledged tobacco as the number one cause of preventable death for decades now, and CMS has taken the lead in implementing coverage policy for our seniors to deal directly with this critical health problem."

In 1993, smoking cost the Medicare program about $14.2 billion, or approximately 10 percent of Medicare's total budget. On average, nonsmokers survived 1.6-3.9 years longer than those who have never smoked.

The proposed new coverage policy is available for review at the CMS coverage Web site (www.cms.hhs.gov/coverage (http://www.cms.hhs.gov/coverage)). The posting of this proposed coverage policy marks the beginning of a 30-day public comment period. After close of the comment period, CMS will have 60 days to review the comments and issue a final policy.

###

Note: All HHS press releases, fact sheets and other press materials are available at http://www.hhs.gov/news (http://www.hhs.gov/news).

Last Revised: December 23, 2004

[Scott Crespy]

The New York Times published two articles by Robert Pear, this past week on the proposed Medicare coverage for smoking cessation counseling. The 12/24/04 article includes the information from the 12/23/04 article and adds more details as well:

12/24/04 - Medicare to Add Help for Smokers (http://www.gainesville.com/apps/pbcs.dll/article?AID=/20041224/ZNYT04/412240306/-1/wire03) (Gainsville.com)

12/23/04 - Medicare to Subsidize Stop-Smoking Counseling (http://www.nytimes.com/2004/12/23/health/23cnd-smoke.html?8bl) (NYTimes.com)

Here are some of the highlights:

- The coverage for smoking cessation counseling may be available as early as March 2005.
- Coverage can include up to 4 counseling sessions. Medicare recipients may be eligible for a second round of 4 sessions within a one year period (total of 8 sessions), if a previous attempt fails.
- Medicare may cover counseling by doctor, nurse or other person trained in smoking cessation counseling.
- Medicare's prescription drug benefit in which is schedule to take effect in 2006, is expected to cover smoking cessation treatments prescribed by doctors.

Some public discussion has already begun to occur and there is interest in extending this coverage to all Medicare smokers, not just those who are sick: It's good that Medicare is helping smokers, but it shouldn't be only if you're sick (http://www.fortwayne.com/mld/newssentinel/news/editorial/10521406.htm) (12/28/04, Knight Ridder/Tribune News Service - Editorial in the Orlando Sentinel).

Scott Crespy, PhD
IPRO Smoking Cessation Project Manager

[Linda Mazzella]

This is exciting news that there will be a direct way to bill for smoking cessation counseling. Our respiratory therapy department is asking how they will be able to bill for smoking cessation services either currently or in the future. Especially if ordered by a physician. How are other hospitals able to handle this? Is it folded in or can it be a separate coded service? Thanks, Linda Mazzella, Coordinator Community Health.

[Donna]

Kaiser Daily Health Policy Report posted an interesting story about this. It offers a synopsis of New York Times and Wall Street Journal articles. The article can be found at http://www.kaisernetwork.org/daily_reports/rep_index.cfm?DR_ID=27438

[Scott Crespy]

Jeny member Linda Mazzella is looking for help from other hospitals about ways that Respiratory Therapists may bill for smoking cessation counseling sessions. If you have any advice, experience or input please reply to this post.

The first three replies gain +50 reputation points! (For more on Reputation Points read Share the Love (http://jeny.ipro.org/showthread.php?t=98))

Scott Crespy

[leslie holmberg]

This is exciting news that there will be a direct way to bill for smoking cessation counseling. Our respiratory therapy department is asking how they will be able to bill for smoking cessation services either currently or in the future. Especially if ordered by a physician. How are other hospitals able to handle this? Is it folded in or can it be a separate coded service? Thanks, Linda Mazzella, Coordinator Community Health.

Linda, we have explored some options for direct billing by RT's. It is very difficult. You can charge for many things, but whether you would be reimbursed is another consideration. I would suggest that you discuss some options with your hospital billing department and/or coding department. Most services, even when ordered by the physician, will be included in the DRG or negotiated payment through the insurance. ( For example, for the patient with a diagnosis of MI, a mammogram may be done, but would not be paid for.) There may be some specific situations when an ordered test would be paid by the insurer or by a self-pay patients. We looked measuring CO levels at one time. ( at the bedside by an RT with MD order) A charge could be entered for tracking perposes, but it did not alter the reimbursement. We did not institute this. I have checked withi some others, and they are not aware of any methods. My phone number is 315-458-3600x375. I would be happy to talk with you about this. Leslie

[Scott Crespy]

There has been a tremendous amount of interest in the Proposed Medicare coverage for smoking cessation counseling. For those of you who are interested in learning more information about it, visit the Draft Decision Memo for Smoking & Tobacco Use Cessation Counseling (CAG-00241N) (http://www.cms.hhs.gov/mcd/viewdraftdecisionmemo.asp?id=130) located in the Medicare Coverage Database.

This Memo includes the following Decision Summary:
The Centers for Medicare and Medicaid Services (CMS) proposes the following:

The evidence is adequate to conclude that smoking and tobacco use cessation counseling, based on the current U.S. Public Health Service (PHS) Guideline, is reasonable and necessary for a patient with a disease or an adverse health effect that has been found by the U.S. Surgeon General to be linked to tobacco use, or who is taking a therapeutic agent whose metabolism or dosing is affected by tobacco use as based on FDA-approved information. The counseling may only be provided by individuals trained in tobacco use cessation counseling.

Minimal counseling is already covered at each evaluation and management (E&M) visit. Beyond that, Medicare proposes to cover 2 cessation attempts per year. Each attempt may include a maximum of four intermediate or intensive sessions, with the total annual benefit covering up to 8 sessions in a 12 month period. The practitioner and patient have flexibility to choose between intermediate or intensive cessation strategies for each attempt.

CMS requests public comments on this proposed decision memorandum pursuant to Section 731 of the Medicare Modernization Act. After considering the public comments, we will issue a final decision memorandum.as well as:

Draft Decision Memo
I. Proposed Decision
II. Background
III. History of Medicare Coverage
V. General Methodological Principles
VI. Evidence


In this decision, a statement is included that mentions the requirement of provider trainingThe counseling may only be provided by individuals trained in tobacco use cessation counseling.but does not seem to specify what would constitute adequate smoking cessation training. Several of you have already asked me about this issue.

If you become aware of any information regarding the training issue or about this decision in general, please contribute to this discussion by posting a reply and sharing it with us.

View the CMS Tracking Sheet (http://www.cms.hhs.gov/mcd/viewtrackingsheet.asp?id=130) to see current status of this issue. You may be interested in seeing the Public Comments (http://www.cms.hhs.gov/mcd/viewpubliccomments.asp?nca_id=130) as well. Thanks.

Scott Crespy, PhD
IPRO Smoking Cessation Project Manager

[Scott Crespy]

On amednews.com, an online publication of the American Medical Association, Stephanie Stapleton, an AMNews staff writer, provides a nice overview of smoking cessation needs of the elderly in "Never too old to quit: You can help the elderly stop smoking (http://www.ama-assn.org/amednews/2005/02/21/hlsa0221.htm)" (2/21/05). She mentions some of the proposed changes in Medicare reimbursement and writes about fact that the AMA has been supportive of these efforts. It appears that we may learn more next month (March, 2005).

Scott Crespy

[Patricia Briest]

Scott, I thought Medicare was planning to begin coverage for cessation counseling in March (this month!) I cannot seem to find it as I try to navigate their website. Can you or anyone else help? Thanks.
Patt

[Scott Crespy]

Hi Patt and other community members,

It is my understanding that 23 March 2005 is the deadline for some decision to be made regarding Medicare coverage for smoking cessation counseling. I think that it might be reasonable to expect to hear something shortly thereafter, unless the deadline is extended.

Scott Crespy, PhD
IPRO Smoking Cessation Project Manager

[Patricia Briest]

Thank you, Scott!

[Scott Crespy]

Here is the announcement that we have been waiting for:


MEDICARE NEWS: For Immediate release
CMS Office of Media Affairs
March 22, 2005
MEDICARE ADDS COVERAGE OF SMOKING AND OTHER TOBACCO USE CESSATION SERVICES

The Centers for Medicare and Medicaid (CMS) today announced it is adding coverage for smoking and tobacco use cessation counseling for certain beneficiaries that will help them quit the habit.

"Covering smoking and tobacco use cessation counseling for seniors has great potential to save and improve lives for millions of seniors," said CMS Administrator Mark B. McClellan, M.D., Ph.D. "This is another step in turning Medicare into a prevention-oriented health program."

The coverage decision, which was proposed for public comment in December, involves Medicare beneficiaries who have an illness caused or complicated by tobacco use, including heart disease, cerebrovascular disease, lung disease, weak bones, blood clots, and cataracts - the diseases that account for the bulk of Medicare spending today. It also applies to beneficiaries who take any of the many medications whose effectiveness is complicated by tobacco use - including insulins and medicines for high blood pressure, blood clots and depression.

Public comments generally supported the approach that CMS proposed, although some commenters preferred broader coverage of all tobacco users. CMS modified the proposal in response to comments by removing a requirement that providers have uniform training in smoking and tobacco use cessation counseling, since no nationally accepted standards exist. When standards do become available, CMS plans to consider whether to add those requirements to its coverage policy.

"Millions of Medicare beneficiaries have smoked for many years, and are now experiencing the heart problems, respiratory problems, and many other often-fatal diseases that smoking can cause," McClellan said. "It's really hard to quit, but we are going to do everything we can to help. I especially want to urge smokers on Medicare who are just starting to experience heart problems or lung problems or high blood pressure to take advantage of this new step."

The Centers for Disease Control and Prevention (CDC) has estimated that 9.3 percent of Americans age 65 and older smoke cigarettes. About 440,000 people die annually from smoking related disease, with 300,000 of those deaths in those 65 and older. CDC estimated in 2002 that 57 percent of smokers age 65 and over report a desire to quit. Currently, about 10 percent of elderly smokers quit each year, with 1 percent relapsing.

"The evidence fully supports the hope that seniors with diseases and health effects caused by smoking and tobacco use can quit, given the right assistance," McClellan said.

The CMS decision to cover cessation counseling comes in response to a June, 2004 request from the Partnership for Prevention (PFP). The PFP requested CMS open a National Coverage Decision (NCD) to consider coverage of tobacco cessation counseling as detailed in the U.S. Department of Health and Human Services, Public Health Service (PHS) 2000 Clinical Practice Guideline: Treating Tobacco Use and Dependence.

The PHS 2000 Guideline has been endorsed by many healthcare and professional organizations. Based on the evidence that is reflected in the guidelines, CMS had decided to extend smoking and tobacco use cessation coverage to beneficiaries who smoke and have been diagnosed with a smoking related disease or are taking certain drugs whose metabolism is affected by tobacco use. This announcement builds on a series of HHS initiatives designed to help Americans quit smoking, including the opening of a new national quitline (1-800-QUITNOW) and designating all HHS campuses tobacco-free.

While many may think that those who quit at age 65 or older fail to reap the health benefits of abstinence from tobacco, the U.S. Surgeon General has reported that the benefits of cessation do extend to quitting at older ages. Smoking cessation in older adults leads to significant risk reduction and other health benefits, even in those who have smoked for years.

Medicare's upcoming prescription drug benefit will cover smoking cessation treatments that are prescribed by a physician.

"Federal policy has acknowledged tobacco as the number one cause of preventable death for decades now, and CMS has taken the lead in implementing coverage policy for our seniors to deal directly with this critical health problem," said Sean Tunis, M.D., CMS' Chief Medical Officer.

Researchers estimate that smoking accounts for approximately 10% of the total costs of the Medicare program or about $20.5 billion in 1997. On average, nonsmokers survived 1.6-3.9 years longer than those who have never smoked.

The final Medicare coverage decision is available on the CMS Website at https://www.cms.gov/coverage/.


###

Please find details of this announcement in the Decision Summary (http://www.cms.hhs.gov/mcd/viewdecisionmemo.asp?id=130) on the Medicare Web-site .

As we all get familiar with the details of this smoking cessation coverage, please share your understanding of how your institution will be able to incorporate this new coverage in your current cessation services. Thanks.

Scott Crespy, PhD
IPRO Smoking Cessation Project Manager

[Scott Crespy]

In the Decision Summary, clarification of coverage for smoking cessation counseling for hospital inpatients was provided in response to comments received:


Inpatient Treatment

Twelve commenters requested that Medicare coverage of smoking cessation counseling services be made available to beneficiaries who are smokers and who are hospital inpatients. We agree with many of these commenters that Part B coverage of intermediate and intensive smoking cessation counseling services specified in the final Decision Memorandum should be available to beneficiaries who are smokers and who are hospital inpatients, as long as those services are furnished by qualified physicians and other Medicare-recognized practitioners. Those qualified practitioners include physicians, physician assistants, nurse practitioners, clinical nurse specialists, and clinical psychologists who are recognized in the Medicare law as being eligible to provide and bill Medicare Part B separately for services that are furnished to hospital patients. However, Medicare Part B coverage will not be available in the final coverage criteria for brief counseling services of less than 3 minutes. Services of less than 3 minutes are considered to be included in each of the inpatient evaluation and management services.

CMS is charged with the evaluation of whether treatments are reasonable and necessary for the treatment of illness in the Medicare population. None of the evidence reviewed suggested inpatient hospital stays with the principal diagnosis of 305.1, Tobacco Use Disorder, absent any other procedures, were reasonable or necessary for the effective delivery of tobacco cessation counseling services. Therefore, Medicare will not reimburse for tobacco use cessation services if tobacco use cessation is the primary reason for the patient’s hospital stay.
These and other details are available in the Medicare Decision Summary (http://www.cms.hhs.gov/mcd/viewdecisionmemo.asp?id=130) (http://www.cms.hhs.gov/mcd/viewdecisionmemo.asp?id=130).

Please consider contributing to this discussion by sharing how you think this coverage might have an impact on the cessation services at your hospital. Thanks.

Scott Crespy, PhD
IPRO Smoking Cessation Project Manager

[Patricia Briest]

Although this is a wonderful development for both Medicare beneficiaries and their providers, both RNs and RTs should certainly be able to provide counseling for tobacco use. RTs see nearly all smokers who are hospitilized for problems exacerbated by tobacco use, and RNs have knowledge base that qualifies them to counsel as well. The programs which I have attended which teach cessation counseling (Freedom from Smoking, Mayo Clinic's Nicotine Dependence seminar, Motivational Interviewing seminars) are consistent with the professional scope of practice for both RTs and RNs. I think Medicare is making this too restrictive. Hospitals and physicians' offices are more likely to have an RN available to provide counseling than others sited. You can bet that reimbursement will not begin to compensate time spent counseling by an MD, NP, or PA.

Patt Briest, MS, FNP-C

[Scott Crespy]

As we begin to more closely examine the smoking cessation Decision Summary, we can begin to see some of its promise and limitations. As we have learned over the course of the past year during the smoking cessation collaborative, a great deal of cessation counseling in the hospital setting is conducted by nurses and respiratory therapists. I agree with you Patt that these providers are an excellent resource, who are in a wonderful position to provide this counseling (and I hope that they continue to do the great work that they have been doing!).

While it appears that Clinical Nurse Specialists and Clinical Psychologists, physicians, PAs and NPs will be able to be reimbursed separately (through Medicare Part B coverage) for the smoking cessation coverage, as you point out, some other professionals, who are clinically qualified, probably won't be able to. In the Decision Summary for the hospital setting it appears that some things have changed and some things have stayed the same. What appears to have changed is an ability for some providers to begin to bill for smoking cessation counseling in a way that was not available in the past. What appears to be staying the same is that only the specialties that currently can bill separately for Medicare Part B services will be able to bill for this service.

It is my understanding that the cost of the services provided by nurses and RTs (and other healthcare providers in hospitals who do not bill separately under the current reimbursement structure) is considered to be "bundled" into the care that the hospital submits to Medicare for a specific diagnosis or procedure.

In sum, it looks like while there was an expansion in coverage, the list of providers who are able to bill separately has not changed.

Is this how others read the Decision Summary? Please contribute toward this discussion by posting your understanding with us (Thanks Patt!)!

Scott Crespy, PhD
IPRO Smoking Cessation Project Manager

[Patricia Briest]

Scott, thank you for putiing this in perspective.

Patt

[Scott Crespy]

Patt, my pleasure (hope I am reading it right though!). There are still some aspects of the Decision Summary that I am not clear about. For example, in section III. "History of Medical Coverage" (see quote below) - Clinical Social Workers (i.e., Section 1861 (s)(2)(N) Clinical social worker services) appear to be included in the smoking cessation coverage, however they are not listed in the "Inpatient Treatment" section (posted earlier). Does anyone know whether clinical social workers can normally bill for Medicare Part B services provided in the hospital setting and why they would not therefore be included?
III. History of Medicare Coverage

The Centers for Medicare & Medicaid Services (CMS) has not previously issued a National Coverage Determination for smoking and tobacco use cessation counseling. Local Medicare contractors currently have discretion to cover these services when they determine them to be medically necessary for the individual patient. The benefit categories for smoking cessation counseling are the following, as defined in the Social Security Act:

Section 1861(s)(1) Physicians' services.

Section 1861(s)(2)(A) Service furnished as an incident to a physician's professional service.

Section 1861 (s)(2)(B) Outpatient hospital services.

Section 1861 (s)(2)(E) Rural health clinic services and federally qualified health center services.

Section 1861(s)(2)(K) Services which would be physicians' services if furnished by a physician and which are performed by a physician assistant (subsection (i)), nurse practitioner or clinical nurse specialist (subsection (ii)).

Section 1861 (s)(2)(M) Qualified psychologist services.

Section 1861 (s)(2)(N) Clinical social worker services.

Self-administrable pharmacotherapy for the purpose of tobacco use cessation is not currently a covered benefit. Under Medicare Modernization Act (MMA) of 2003 Part D drugs are defined to include certain smoking cessation agents beginning in January of 2006.


I know we have a rich knowledge base in our community, please consider sharing your insights and experience with us on these issues. Thanks.

Scott Crespy, PhD
IPRO Smoking Cessation Project Manager

[Scott Crespy]

Clinical Social Worker Coverage Clarification:

It is my understanding that in the inpatient setting, clinical social workers are not eligible to bill separately for Medicare part B coverage and this is why they are not included as a provider in the Inpatient Treatment section of the Decision Summary. There may be other issues as well, such as, the need to bill for a service related to a physical health condition and not a mental health condition.

Scott Crespy, PhD
IPRO Smoking Cessation Project Manager

[Scott Crespy]

The Department of Health & Human Services, Center for Medicare and & Medicaid Services posted the following documents regarding Smoking Cessation Coverage:

1. CMS Manual System (Pub. 100-03) Medicare National Coverage Determinations - SUBJECT: Smoking and Tobacco-Use Cessation Counseling (http://www.cms.hhs.gov/manuals/pm_trans/R36NCD.pdf) Dated: MAY 20, 2005

2. CMS Manual System (Pub. 100-04) Medicare Claims Processing Centers - SUBJECT: Smoking and Tobacco-Use Cessation Counseling Services (http://www.cms.hhs.gov/manuals/pm_trans/R562CP.pdf) Dated: MAY 20, 2005

New York State facilities and providers, please join us on a Wednesday, June 22, 2005 conference call to learn more about this new coverage. Learn More (http://jeny.ipro.org/announcement.php?f=21)

Please feel free to review these documents and share your ideas about your plans to incorporate this coverage change in your practice and/or facility. We look forward to your comments.

Scott Crespy, PhD
IPRO Smoking Cessation Project Manager

[heidis]

I have a question regarding correct coding of ICD-9 codes for reimbursement for tobacco cessation counseling. Are there specific diagnosis codes required in order to be reimbursed when billing G0375 or G0376? Also, where can I find a listing of the medications or therapeutic agents whose metabolism may be affected by tobacco use. Thank you.

[Fran Chambers]

Heidis, the New York State Health Department Tobacco Cessation Centers joint with IPRO hosted a conference call on June 22 which discussed the various qualifications for reimbursement for tobacco cessation counseling. Among these were diagnoses that are appropriate and medications which are affected by tobacco use and would therefore qualify. The transcription of the conference call will be uploaded to the JENY site as soon as they are completed. This may take a short while, but keep checking. As far as the actual ICD-9 codes, you should be able to match the codes to the diagnoses when you see them in print.

Also, reference Dr. Kathleen Terry regarding coding:
" The official coding guidelines for ICD-9-CM have been updated March 16, 2005. These guidelines are effective April 1, 2005.

http://www.cdc.gov/nchs/data/icd9/icdguide.pdf
I hope this is helpful.

[Patricia Briest]

Fran is correct! A lot of content was included in the June 22 Conference call. As soon as information from the call is posted, we will all be in a better position to apply these codes appropriately. Since the speakers were difficult to hear at times, and so much content was given rapidly, the post should address questions we may have. This is "new" territory for all of us, so we certainly should expect a "learning curve" (however, Medicare may not agree!)

Patt

[Scott Crespy]

Dr. Joseph Presto E-mailed me today with the following information: I did investigate the question of performing smoking cessation counseling during an inpatient (or outpatient) surgical global period. Since these are separate benefits, and since smoking counseling is not related to the surgical procedure, smoking cessation can be billed separately. However, in the inpatient hospital setting this could only be billed by a qualified physician or qualified Medicare-recognized non-physician practitioner who is performing this as an individual private service and not as an employee of the hospital. No modifiers are needed to bill G0375 or G0376. Thank you. Scott Crespy