Summary & Overview
HCPCS G9381: Documentation of Reasons for Not Offering End-of-Life Assistance
HCPCS Level II code G9381 records when clinicians document medical reasons for not offering assistance with end-of-life issues during a measurement period (for example, when a patient is enrolled in hospice or is in a terminal phase). Nationally, standardized documentation of such reasons informs quality reporting, continuity of care, and appropriate attribution of missed or withheld end-of-life discussions.
This publication covers common national payers including Aetna, Blue Cross Blue Shield, Cigna Health, UnitedHealthcare, and Medicare. Readers will find concise benchmarks and context around clinical documentation practice, implications for quality measurement, and relevant policy or reporting considerations where available. The material outlines how G9381 is used to reflect documented clinical circumstances that justify why end-of-life assistance was not offered, and how that documentation interacts with quality measurement frameworks.
The report provides: an operational summary of the code's clinical intent; payer coverage considerations and typical sites of service; and guidance on what types of dashboards and reports can reference G9381 for measurement purposes. Data not provided in the input (such as specific modifiers, taxonomies, ICD-10 pairings, or detailed payer policy language) are indicated as unavailable.
Billing Code Overview
HCPCS Level II code G9381 documents the medical reason(s) for not offering assistance with end of life issues during the measurement period (for example, patient in hospice care or patient in a terminal phase). This code captures situations where a clinician records why end-of-life assistance or conversations were not provided or offered to the patient within the reporting timeframe.
Service type: Documentation / Clinical Assessment
Typical site of service: Inpatient settings or hospice care settings, and other clinical encounters where end-of-life status is assessed
Data not available in the input for modifiers, associated taxonomies, ICD-10 diagnoses, related codes, and service line.
Clinical & Coding Specifications
Clinical Context
A typical patient scenario involves an adult with advanced terminal illness who is established in primary care or a specialty clinic and who either is enrolled in hospice or is clearly in the terminal phase of a life-limiting disease. During the measurement period a clinician documents that assistance with end-of-life issues (for example, goals-of-care discussion, advance care planning, palliative care referral, or hospice counseling) was considered but not offered because of documented medical reasons. Example: an 82-year-old patient with metastatic pancreatic adenocarcinoma admitted to the clinic for routine follow-up. The patient is already enrolled in a Medicare-certified hospice program and is receiving comfort-focused care. The clinician documents that assistance with additional end-of-life interventions or hospice initiation was not offered because the patient is already in hospice and the goals of care are consistent with hospice services.
Clinical workflow:
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The clinician reviews the patient chart and confirms hospice enrollment or terminal status.
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During the encounter, the clinician documents the specific medical reason(s) for not offering end-of-life assistance, such as active enrollment in hospice, imminent death/terminal phase, or documented patient directive that declines additional services.
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The documentation is entered into the medical record during the measurement period and coded with
G9381to indicate a medical reason for not offering assistance with end-of-life issues. -
The encounter note is reviewed by coding staff to ensure the note supports
G9381and any relevant ICD-10 codes are linked for the claim.
Coding Specifications
| Modifier | Description | When to Use |
|---|---|---|
25 | Significant, separately identifiable evaluation and management service by the same physician on the same day of the procedure or other service | Use if a distinct E/M visit was provided in addition to documentation supporting G9381 on the same date of service |
59 | Distinct procedural service | Use when services on the same date are distinct and separate from the documentation represented by G9381 |
24 | Unrelated evaluation and management service by the same physician during a postoperative period | Use if G9381 is reported during a postoperative global period and the encounter is unrelated to the prior procedure |
57 | Decision for surgery | Use when the visit resulted in the decision for surgery and documentation of not offering end-of-life assistance is also present |
26 | Professional component | Use if billing is split between professional and technical components and G9381 pertains to the professional component |
52 | Reduced services | Use if services on the claim were reduced or partially performed and documentation explains the reduction in the context of terminal/hospice status |
KX | Requirements specified in the medical policy are met | Use when payer-specific policy requires attestation and documentation supports the exception (payer-specific use) |
GA | Waiver of liability statement on file (Advanced Beneficiary Notice) | Use if applicable payer requires ABN-like documentation and the patient has executed a waiver |
XE | Separate encounter, a service that is distinct because it occurred during a separate encounter | Use when the documentation for not offering assistance occurred in a separate visit from other services on the same date |
XP | Separate practitioner | Use if a different practitioner provided the service/documentation than other services reported on the same day |
| Taxonomy Code | Specialty | Notes |
|---|---|---|
208000000X | Internal Medicine | Primary care clinicians who regularly document care planning and hospice status |
207Q00000X | Hospice and Palliative Medicine | Specialists who assess end-of-life issues and document reasons for not offering additional assistance |
207R00000X | Family Medicine | Family physicians who manage chronically ill patients and document hospice/terminal-phase decisions |
207W00000X | Geriatric Medicine | Clinicians focused on older adults with terminal illnesses who document goals of care |
208600000X | Pulmonary Disease | Specialists caring for advanced chronic lung disease patients where hospice enrollment is common |
Related Diagnoses
| ICD-10 Code | Description | Clinical Relevance |
|---|---|---|
Z51.5 | Encounter for palliative care | Directly relevant when the patient is receiving palliative services and additional end-of-life assistance is not offered |
Z51.0 | Encounter for antineoplastic chemotherapy and immunotherapy | Patients actively receiving cancer-directed therapy may still have documented reasons for not offering hospice or further end-of-life assistance |
C80.1 | Malignant neoplasm, unspecified, metastatic site | Indicates advanced cancer or metastatic disease often associated with hospice enrollment or terminal status |
R99 | Ill-defined and unknown cause of mortality | Used in contexts describing terminal phase where definitive cause or transition to end-of-life care is documented |
Z66 | Do not resuscitate status (DNR) | Documentation of DNR or similar directives supports the medical reason for not offering additional end-of-life interventions |
Related CPT Codes
| CPT Code | Description | Relationship to This Procedure |
|---|---|---|
99497 | Advance care planning including the explanation and discussion of advance directives, first 30 minutes | May be performed when offering assistance with end-of-life issues; absence of this service may be documented with G9381 if not offered for medical reasons |
99498 | Advance care planning including the explanation and discussion of advance directives, each additional 30 minutes | Used when longer advance care planning is provided; contrast with G9381 which documents reasons for not offering such assistance |
99406 | Smoking and tobacco cessation counseling, intermediate, greater than 3 minutes up to 10 minutes | Example of an unrelated counseling service that may occur on same day; modifier usage may distinguish these from G9381 documentation |
99214 | Office or other outpatient visit for the evaluation and management of an established patient, moderate complexity | Typical E/M code for encounters where documentation of not offering end-of-life assistance is made |
99377 | Physician oversight of hospice care (subsequent), per diem | Related to hospice care management; G9381 is used when additional assistance is not offered because hospice services are already in place |