The current CMS instruction is Transmittal 13944, Change Request 14495. It replaces Transmittal 13860, which CMS issued on July 10. The effective date remains January 1, 2027, with an implementation date of January 4, 2027. CMS specifically says the September transmittal rescinds and replaces the July version because CMS deleted one of the original business requirements. All of the other information remains the same.
So let’s break down what hospice teams actually need to know. Beginning January 1, when a hospice physician or hospice nurse practitioner completes the required recertification face-to-face encounter using telecommunications technology, the hospice must report that encounter on the hospice claim using HCPCS code G0679. CMS defines G0679 specifically for a hospice face-to-face encounter conducted by a hospice physician or hospice nurse practitioner for recertification using telecommunications technology. CMS also considers this telehealth encounter an administrative expense.
The code itself is only one part of getting the claim right. Under the current instructions, G0679 is reported on hospice claims using Type of Bill 81X or 82X and revenue code 0657. The telehealth face-to-face encounter must also be reported in line-item detail as a separately dated line. If G0679 is submitted on the wrong type of bill or with a revenue code other than 0657, CMS instructs the Medicare contractor to return the claim to the provider.
In simple terms, beginning January 1, your billing team needs to know three things: the telehealth recertification face-to-face encounter is reported with G0679, it needs to be associated with revenue code 0657, and it needs to be reported correctly on the hospice claim. This is not something I would expect a hospice administrator or clinical leader to memorize, but somebody in your organization absolutely needs to know it, and your EMR and billing software need to be built correctly to capture it.
The September 2 change is where this gets particularly interesting. The original July instructions contained an additional requirement, identified by CMS as business requirement 14495.4. That instruction would have required the Medicare contractor to return a claim when G0679 with revenue code 0657 appeared without another service on the claim. When CMS issued the replacement transmittal on September 2, it specifically deleted that requirement.
That means if your billing department created an internal checklist based on the July instructions, or your vendor began programming its system based on that earlier version, they need to go back and make sure they are now following Transmittal 13944. This is not simply a new copy of the same instructions. CMS intentionally removed one of the claim edits from the original version.
This is also why I would not wait until December to ask your vendor whether they are ready. There are several different people involved in getting this right. The physician or nurse practitioner has to complete the appropriate face-to-face encounter. The hospice has to capture that it was performed using telecommunications technology. The information has to make it through the EMR correctly. The billing system has to translate that information onto the claim correctly, and the claim has to contain the right code, revenue code, type of bill, and date information.
The clinical requirement for hospice face-to-face encounters itself is not new. Medicare has required a hospice physician or nurse practitioner to conduct a face-to-face encounter before the 180th-day recertification and before each subsequent recertification for years. What is changing January 1 is the claims-reporting requirement when that encounter is performed using telecommunications technology.
I think this is an important distinction for clinical teams. G0679 is not a new type of hospice visit that suddenly begins in January. It is a new way CMS is requiring hospices to identify on the claim that the required recertification face-to-face encounter was conducted using telecommunications technology.
Hospice leaders also need to remember that a perfectly appropriate clinical encounter can still create a billing problem if the claim isn’t submitted correctly. The patient can be eligible. The physician or NP can complete the encounter appropriately. The documentation can support the recertification. None of that prevents a claim from being returned because the billing information was submitted incorrectly.
That is why I would put this on your January 1 implementation list now. Ask your billing team whether they have the September 2 version of Change Request 14495. Ask your EMR and billing vendors whether their January update is being built from Transmittal 13944 rather than the rescinded July Transmittal 13860. Make sure they understand that the old requirement involving another service on the claim was deleted. Then test the process before January if your system allows you to do that.
I would also save a copy of the September 2 CMS instruction with your internal billing guidance. CMS has already replaced one version of these instructions, and there is no reason to leave your team trying to remember which document they downloaded or which email contained the newest information. Give everyone one authoritative source and make sure that is what your internal procedures and vendor configuration are based on.
This may sound like a small technical billing change, and in many ways it is. But these are exactly the small changes that become frustrating and expensive when they are missed. A returned claim means somebody has to find the problem, correct it, resubmit it, and wait for payment. Multiply that across multiple patients and multiple claims, and a small coding issue can quickly become a cash-flow and administrative problem.
It is also another example of why hospice compliance has become so much broader than chart auditing alone. Clinical documentation still matters tremendously, but compliance also means making sure billing, operations, technology, and clinical processes are all working together. CMS can change one technical instruction and suddenly your clinical team, billing department, EMR vendor, and leadership all have a piece of the implementation.
At The Amity Group, our Audit Protection & Compliance Division helps hospice organizations stay ahead of changes like these while also reviewing the clinical records and operational processes that ultimately protect reimbursement. The goal is not simply to find problems after claims are returned or records are requested. It is to identify vulnerabilities early enough that leadership still has time to do something about them.
January 1 will be here quickly. Make sure your team knows the new code is G0679, make sure your billing and EMR vendors are working from the September 2 CMS instructions, and make sure the old July version has not quietly become the instruction everyone in your organization is still following.
Shelley Henry, RN
President, The Amity Group, Inc.
AmityStaffing.com
