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Physicians and Care Plan Oversight (CPO) and Certification/Recertification

Susan Carmichael

Care Plan Oversight is physician supervision of patients under either the home health or hospice CMS benefit. CMS does not provide this reimbursement for these services if a patient resides in a nursing facility or skilled nursing facility.

Physicians should be made aware of this reimbursable service. They must review the Plan of Care and be made aware of the reimbursement for the process.

Understand the Difference between CPO and Certification/Recertification

G0180 Certification of a home health patient
G0179 Recertification of a home health patient
G0181 Home Health Care Plan Oversight
G0182 Hospice Care Plan Oversight

Care Plan Oversight reimbursement allows physicians to bill CMS for the time physicians oversee the home health plan of care. The physician may bill for 30 minutes of time each month as long as they log the care delivered and it is allowable care for CPO. 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.

Certification billing requirements include:

  • The physician signing the Plan of Care is the physician who may bill for CPO
  • Date of Service: Date the physician signs the POC
  • List home health agency provider number
  • List physician NPI number
  • List the care provided that meets the required services for payment

Recertification billing requirements:

  • Must be billed by the physician who recertified the patient
  • Used after a patient has received 60 days of covered skilled intermittent Medicare services
  • Date of service: Date the physician signed the POC
  • List agency provider number
  • List physician NPI number

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 with the hospice.

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

Non – Countable 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

Billing/Filing the Claim

Medical records for the dates must document the 30 or more allowable minutes for care planning activities for each patient. Dates of services must be the first and last date during which documented planning services were provided. No other services, but from the CPO may be on the claim.

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.

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