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Physicians and Care Plan Oversight (CPO)

Physicians and Care Plan Oversight (CPO) is physician supervision of patients under either the home health or hospice benefit where the patient requires complex or multi-disciplinary care requiring ongoing physician involvement. Medicare does not pay for care plan oversight services for nursing facility or skilled nursing facility patients.


Separate payment is allowed for the services involved in physician certification/re-certification and development of a plan of care for Medicare covered home health services.

Submit HCPCS code G0179 for re-certification after a patient has received services for at least 60 days (or one certification period). HCPCS code G0179 may be reported only once every 60 days, except in the rare situation when the patient starts a new episode before 60 days elapses and requires a new plan of care to start a new episode.

Submit HCPCS code G0180 when the patient has not received Medicare covered home health services for at least 60 days. The initial certification (HCPCS code G0180) cannot be filed on the same date of service as the supervision service HCPCS codes (G0181 or G0182).


  • G0179: Recertification of a Home Health Patient
  • G0180: Certification of a Home Health Patient
  • G0181: Home Health Care Supervision
  • G0182: Hospice Care Supervision


updated 3/25/2015

Frequently Asked Questions

What is CPO?

CPO is physician supervision and oversight of patients under either home health G0181 or the CMS hospice benefit G0182. The home health services may include:

  • Developing an individualized plan of care
  • Telephone calls with other health care physicians involved with the care
  • Revising a plan of care
  • Activities involving coordinating of care
  • Documentation of planning
  • Medical Decision Making
  • Review of treatment plans, and analysis of labs, tests, and data analytics
  • Team conferences

The beneficiary must require complex and/or interdisciplinary care. The physician may not have a significant financial or contractual interest in the home health agency. The physician may not be the medical director or employee of the hospice, and does not provide service under arrangement.

How do I Submit a Claim?

Submit CPT codes 99201-99263and 99281-99357 only when there has been a face-to-face meeting/encounter

HHA / Hospice Provider Number: The requirement to include the HHA or Hospice provider number on a care plan oversight claim for HCPCS codes G0181 and G0182 is waived until further notice, and as a result, claims submitted with the number will be rejected.

Dates of Service

HCPCS codes G0181 and G0182

Submit the first and last date during which documented care planning services were actually provided during the calendar month.

  • Do not submit the first and last calendar date of the month unless services were provided on those dates)
  • Submit the claim after the end of the month in which the service is performed
  • Report care planning only once per calendar month
  • Report only one month’s services per line item

HCPCS codes G0179 and G0180

Submit the date physician signed the certification or re-certification.

What Documentation is Required?

What Documentation is Required?

Claims for care plan oversight services will be denied when review of the beneficiary claims history fails to identify a covered physician service requiring a face-to-face encounter by the same physician during the six months preceding the provision of the first care plan oversight service

Medical records for these services must indicate:

  • The physician spent 30 minutes or more for countable care planning activities
  • The specific service furnished, including the date and length of time

What are the Recertification Billing Requirements?

The claim must be billed by the physician who re-certified the patient. Used after a patient has received 60 days of covered skilled intermittent Medicare services.

Who Must Complete the Documentation?

The documentation must be completed by the physician and not the home health agency.

Which Services are not Billable?

You may not bill for the following services.

  • Initial interpretation of a lab during a face to face encounter
  • Informal calls with office personnel
  • Telephone calls to patients, family, even if medication adjustment occurs
  • Travel time
  • Time preparing claims

Helpful Tip

Agencies should spend the time to educate physicians to this reimbursement possibility. Have a simple fact sheet available with the steps to complete the process identified but do not complete the form for the physician. Offer a sample log to physicians so they may see what can be billed.  Provide the link to the CMS site so the physicians may read the complete process outlined by CMS.

Remember the Face to Face encounter must be included as part of the certification form itself, or as a signed addendum to it, and must include the certifying physician’s distillation of the patient’s clinical condition and needs for home care. It must also attest to homebound status and medical necessity.

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