Let me begin by giving credit where credit is due - the content for this blog post comes entirely from the IPRCM crew via my old friend, Susanne Morgana Brennan. She shared it with me and I asked if I could share it here (she graciously agreed, obviously). Anyone who knows me should know how I feel about patient privacy, an issue particularly sensitive in the face of the perverse intent of our present administration to harm a subset of children. There are things we can do to protect them. Even when we're talking about billing and coding.
From: IPRCM Billing Team
Date: March 11, 2025
Subject: Coding and Billing for Transgender Care While Protecting Patient Confidentiality
As laws and policies affecting transgender healthcare continue to evolve, we recognize the challenges pediatric providers face when coding and billing for gender-affirming care, especially when families request discretion to protect their children’s privacy. Ensuring proper payment while safeguarding patient confidentiality is paramount, particularly in states where transgender healthcare is subject to increased governmental scrutiny.
To support your practice in navigating this sensitive issue, we offer the following guidelines:
1. Use General Diagnosis Codes When Appropriate
When providing care related to gender-affirming treatment, consider utilizing non-specific diagnosis codes where clinically appropriate, such as:
- R45.89 – Other symptoms and signs involving emotional state
- Z71.89 – Other specified counseling (for general counseling visits)
- Z13.39 – Encounter for screening examination for other mental health and behavioral disorders (if evaluating for concerns related to gender identity without explicitly stating it)
2. Avoid Direct Gender Dysphoria Codes if Privacy Is a Concern
Although F64.9 (Gender identity disorder, unspecified) is a valid code, using this in sensitive situations may not align with a family's privacy concerns. Consider whether alternative coding strategies meet medical necessity while maintaining confidentiality.
3. Utilize Preventive and Primary Care Codes
Routine visits for discussions about mental health, growth and development, or general well-being can often be billed under:
- 99213-99215 – Office or other outpatient visit for an established patient (based on medical decision-making or time spent)
- 99401-99404 – Preventive medicine counseling and risk factor reduction interventions (time-based)
4. Prescriptions and Lab Orders
When ordering labs or prescriptions related to gender-affirming care, consider whether a general endocrinology, adolescent medicine, or mental health-related diagnostic code is appropriate.
5. Documentation Considerations
Maintain thorough clinical documentation while being mindful of the language used in visit notes, ensuring that necessary medical information is recorded while minimizing risk to patient confidentiality.
6. Insurance and Prior Authorization
Some insurers may require specific gender identity-related diagnoses for coverage. If prior authorization is needed, consider separate communications that do not appear in routine visit documentation.
We understand that each case is unique, and we encourage providers to use their best clinical judgment while considering the privacy concerns of their patients. If you have any specific cases requiring additional coding support, our billing team is available to assist you.
Please do not hesitate to reach out to IPRCM for guidance. Thank you for your dedication to providing compassionate and comprehensive pediatric care.
Best regards,
Susanne Brennan
President, IPRCM/IPMSO