Closing HEDIS FUH Gaps: Billing and Diagnostic Codes

As the healthcare landscape continues to evolve, providers face an ever-increasing responsibility to ensure the delivery of quality care. Starting January 1, 2025, a pivotal change will empower both medical and behavioral healthcare providers to take greater control in addressing gaps in care—particularly the follow-up after hospitalization (FUH) for mental illness measure under the Healthcare Effectiveness Data and Information Set (HEDIS®). This change enables providers to use qualified billing and diagnostic codes to close these gaps and improve patient outcomes. 

In this long read, we will explore the importance of the FUH measure, the upcoming changes in billing practices, and actionable steps providers can take to adapt to these changes effectively. 

The Importance of Closing FUH Gaps in Mental Health Care 

The FUH measure focuses on ensuring that patients discharged from an inpatient psychiatric facility receive timely follow-up care to support their recovery and reduce the risk of readmission. Follow-up care is crucial for: 

1. Continuity of Care: Timely follow-up appointments help maintain a therapeutic relationship and ensure patients transition smoothly from inpatient to outpatient care. 

2. Reducing Readmissions: Patients are less likely to relapse or require readmission when they engage in post-discharge care. 

3. Improved Outcomes: Early intervention addresses emerging symptoms and supports adherence to treatment plans. 

4. Compliance with Quality Standards: Meeting FUH HEDIS measures is a marker of high-quality, patient-centered care. 

Despite the clear benefits, FUH gaps persist due to systemic issues such as a lack of integration between inpatient and outpatient settings, insufficient provider availability, and patient barriers like transportation and stigma. 

The 2025 Update: Expanding Opportunities for Providers 

The upcoming change allows medical healthcare providers—alongside behavioral health specialists—to use qualified billing and diagnostic codes to close FUH gaps. This expansion acknowledges the critical role that primary care and other medical professionals play in supporting patients with mental health needs. 

Key Highlights of the Change 

1. Broader Scope of Providers: Medical providers, such as primary care physicians, can now actively contribute to closing FUH gaps, recognizing their role in holistic patient care. 

2. Increased Use of Billing Codes: Providers can use a wide array of billing and diagnostic codes to document FUH care, whether the appointment is in-person, virtual, or via telephone. 

3. Flexibility in Follow-Up Timing: While the ideal follow-up occurs within 7 days post-discharge, appointments within 30 days are also valuable for closing gaps. 

By leveraging this expanded scope, providers can address patients’ physical and mental health needs simultaneously, creating a more integrated approach to post-discharge care. 

Actionable Steps to Close FUH Gaps 

Providers can take several steps to meet the updated FUH requirements and improve care quality: 

1. Prioritize Timely Scheduling 

• Aim to schedule follow-up visits within 7 days of discharge whenever possible. If unavoidable delays occur, ensure the patient is seen within 30 days. 

• Establish workflows to flag discharged patients and prioritize appointment scheduling. 

1. Collaborate Across Disciplines 

• Foster stronger communication between inpatient and outpatient care teams to ensure seamless care transitions. 

• Collaborate with behavioral health specialists to provide comprehensive follow-up care. 

1. Optimize Documentation with Billing Codes 

Using appropriate billing and diagnostic codes is critical for closing FUH numerator gaps in care. 

Key Billing Codes Include: 

• Behavioral Health Visits: 

• 98960–98962, 99078, 99202–99215, 99341–99350, 99381–99397, 99401–99494, and 99510. 

• Outpatient Visits with Mental Health Diagnoses: 

• 90791, 90792, 90832–90840, 99221–99255, and more. 

• Psychiatric Collaborative Care Management: 

• 99492–99494; HCPCS: G0512. 

• Transitional Care Management (TCM): 

• 99495, 99496. 

• Telephone Visits: 

• 98966–98968, 99441–99443. 

Ensure that your billing team is well-versed in these codes to accurately document and report the care provided. 

1. Enhance Patient Engagement 

• Educate patients on the importance of follow-up care for their recovery and well-being. 

• Address barriers such as transportation or stigma by offering telehealth or phone consultations as alternatives. 

1. Implement Technology Solutions 

• Use electronic health records (EHRs) to set reminders for follow-up appointments. 

• Leverage telehealth platforms to provide convenient access to care, especially for patients in remote or underserved areas. 

The Role of Telehealth and TCM in Closing FUH Gaps 

Telehealth and Transitional Care Management (TCM) play critical roles in addressing FUH gaps: 

Telehealth 

• Accessibility: Telehealth enables providers to reach patients who may face barriers to in-person care. 

• Convenience: Patients can receive care from the comfort of their homes, reducing logistical challenges. 

• Effective Documentation: Telehealth visits can be documented using specific billing codes (e.g., 99202–99215, 99441–99443). 

Transitional Care Management 

• Holistic Approach: TCM ensures that patients receive comprehensive support during the vulnerable post-discharge period. 

• High-Impact Codes: Billing codes 99495 and 99496 allow providers to document TCM services, which include medication management, care coordination, and addressing psychosocial needs. 

By incorporating these tools, providers can bridge gaps in care and meet HEDIS FUH requirements effectively. 

Challenges and Solutions 

Despite the opportunities presented by the 2025 update, challenges remain: 

Challenge 1: Limited Provider Availability 

Solution: Expand the use of telehealth and recruit additional providers to handle follow-up care demands. 

Challenge 2: Complex Billing Practices 

Solution: Provide training for administrative and clinical staff on accurate coding and documentation. 

Challenge 3: Patient Barriers 

Solution: Offer flexible scheduling options, transportation assistance, and culturally sensitive care to address common patient barriers. 

The Broader Implications of Closing FUH Gaps 

Meeting FUH requirements is about more than compliance—it’s about transforming the quality of mental health care delivery. 

Improving Patient Outcomes 

Patients who receive timely follow-up care are more likely to adhere to treatment plans, achieve stability, and avoid costly readmissions. 

Strengthening Provider Collaboration 

The integration of medical and behavioral health providers fosters a more holistic approach to care, addressing the full spectrum of patient needs. 

Advancing Equity in Healthcare 

By removing barriers and expanding access, providers can make significant strides in reducing disparities in mental health care. 

The 2025 update to FUH HEDIS measures marks a significant step forward in closing gaps in mental health care. However, success will depend on the proactive engagement of providers, the strategic use of billing and diagnostic codes, and a commitment to patient-centered care. 

By embracing these changes, medical and behavioral health providers can ensure that all patients—especially those most vulnerable—receive the timely, high-quality follow-up care they deserve. Together, we can build a healthcare system that is not only compliant but compassionate, equitable, and effective.