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Coding of Palliative Care in the Home Health Setting


by Joan L. Usher, BS, RHIA, HCS-D, ACE, AHIMA Approved ICD-10-CM Trainer

JLU Health Record Systems

I recently heard from a client regarding coding of palliative care in the home health setting. He asked:

My organization is seeking clarity on the use of Comfort care/Palliative care code Z51.5. I did some research yesterday and found what appears to be conflicting advice from AHA Coding Clinic.

    • Historical ICD-9 guidance isolated code V66.7 (Admission for Palliative Care) as only applicable as a secondary code.
    • More recent guidance suggests to follow the “reason for admission,” thereby allowing code usage (Z51.5 Admission for Palliative Care) as either a secondary diagnosis or principal/first-listed/primary diagnosis.

What do you advise?

This is a great question. In home health, the reason for the encounter is typically not palliative care but rather the condition necessitating the palliative care. Because the HHA care plan is usually focused on disease management, medication management, and comorbidities, Z51.5 Admission for Palliative Care would be an appropriate secondary diagnosis code for home health, hospice, and end of life care settings.

Also note: the palliative care code may be utilized in any setting. For example, if the inpatient encounter is strictly for palliative care/comfort care, then Z51.5 could be utilized as a primary diagnosis along with the code also note to identify condition requiring care.

To capture reimbursement for services, the palliative care provider bills under Medicare Part B while Home Health bills under Medicare Part A.


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About the Author

Joan Usher, BS, RHIA, HCS-D, ACE
Joan is President of JLU Health Record Systems, a leader in Health Information Management and coding solutions. A nationally recognized expert in the field of health information management, Joan has taught coding for over 25 years and has educated over 20,000 people nationwide. She is author of the JLU Rapid Reference Coding Guide, an easy-to-use coding guide in ICD-10 for common home health diagnoses, and author or editor of numerous courses, books and articles on coding, reimbursement methods, clinical documentation improvement, and health record requirements.

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