Hospital Medicine Has a Specialty Code. Is the Memo Still in the Mail?
The Centers for Medicare and Medicaid Services awarded Hospital Medicine a Medicare specialty code, “C6”, in 2016. We examined the early uptake of C6 code using the 2017 Medicare Part B utilization data. We also compared the actual C6 specialty code usage against estimated rates of overall hospitalist billing using threshold-based hospitalist rates of Evaluation and Management codes to assess the integration of the newly introduced code. Billing activity associated with the C6 code was approximately one-tenth of expected rates.
© 2019 Society of Hospital Medicine
In recognizing the importance of Hospital Medicine (HM) and its practitioners, the Centers for Medicare and Medicaid Services (CMS) awarded the field a specialty designation in 2016. The code is self-selected by hospitalists and used by the CMS for programmatic and claims processing purposes. The HM code (“C6”), submitted to the CMS by the provider or their designee through the Provider Enrollment Chain and Ownership System (PECOS), in turn links to the National Provider Identification provider data.
The Society of Hospital Medicine® sought the designation given the growth of hospitalists practicing nationally, their impact on the practice of medicine in the inpatient setting,1 and their secondary effects on global care.2 In fact, early efforts by the CMS to transition physician payments to the value-based payment used specialty designations to create benchmarks in cost metrics, heightening the importance for hospitalists to be able to assess their performance. The need to identify any shifts in resource utilization and workforce mix in the broader context of health reforms necessitated action. Essentially, to understand the “why’s” of hospital medicine, the field required an accounting of the “who’s” and “where’s.”
The CMS granted the C6 designation in 2016, and it went live in April 2017. Despite the code’s brief two-year tenure, calls for its creation long predated its existence. As such, the new modifier requires an initial look to help steer the role of HM in any future CMS and managed care organization (MCO) quality, payment, or practice improvement activities.
METHODS
We analyzed publicly available 2017 Medicare Part B utilization data3 to explore the rates of Evaluation & Management (E&M) codes used across specialties, using the C6 designation to identify hospitalists.
To try to estimate the percentage of hospitalists who were likely billing under the C6 designation, we then compared the rates of C6 billing to expected rates of hospitalist E&M billing based on an analysis of hospitalist prevalence in the 2012 Medicare physician payment data. Prior work to identify hospitalists before the implementation of the C6 designation relied on thresholds of inpatient codes for various inpatient E&M services.4,5 We used our previously published approach of a threshold of 60% of inpatient E&M hospital services to differentiate hospitalists from their parent specialties.6 We also calculated the expected rates of E&M billing for other select specialty services by applying the 2012 E&M coding trends to the 2017 data.
RESULTS
Table 1 shows the distribution of inpatient E&M codes billed by hospitalists using the C6 identification, as well as the use of those codes by other specialists. Hospitalists identified by the C6 designation billed only 2%-5% of inpatient and 6% of observation codes. As an example, in 2017, discharge CPT codes 99238 and 99239 were used 7,872,323 times. However, C6-identified hospitalists accounted for only 441,420 of these codes.
