Care Plan Oversight for Medicare Patients

Medicare has developed two HCPCS codes for providing Care Plan Oversight  (CPO) to their patients.  There are also CPO codes in the CPT® book for non-Medicare patients.  See the article in Codapedia related to the CPO codes for non-Medicare patients.  

For Medicare patients, the service is described as the supervision of the patient who is receiving either Medicare covered Home Health Agency (HHA) services, or Medicare covered hospice services, who requires the supervision for complex care and who are receiving multi disciplinary treatments.  This is one of the few times when Medicare will pay physicians for services that are provided non-face-to-face with their beneficiary.  Typically, Medicare only pays for services that are provided face-to-face with their patients.  

There are two codes:

G0181 -- Physician supervision of a patient receiving Medicare-covered services provided by a participating Home Health Agency (patient not present) requiring complex and multidisciplinary care modalities involving regular physician development and/or revision of care plans, review of subsequent reports of patient status, review of laboratory and other studies, communication (including telephone calls) with other health care professionals involved in the patient's care, integration of new information into the medical treatment plan and/or adjustment of medical therapy, within a calendar month, 30 minutes or more

G0182 -- Physician supervision of a patient under a Medicare-approved hospice (patient not present) requiring complex and multidisciplinary care modalities involving regular physician development and/or revision of care plans, review of subsequent reports of patient status, review of laboratory and other studies, communication (including telephone calls) with other health care professionals involved in the patient’s care, integration of new information into the medical treatment plan and/or adjustment of medical therapy, within a calendar month, 30 minutes or more

The billing and coding rules for this service are complex.  There are specific rules about what may or may not be included in time reported for CPO.  In order to bill for the service, the time spent in these activities must be documented in the medical record, along with a description of the activities, the dates the services were performed and the provider’s signature.

The physician who bills for CPO must be the same physician who certified the patient for home health agency or hospice services.  A qualified Non-Physician Practitioner (NPP) may provide care plan oversight if the NPP has a collaborative agreement with the physician who certified the patient.  Neither the physician nor the NPP providing the service may be an employee or director, paid or voluntary, of either the home health agency or the hospice providing the care or have any significant financial arrangements with one of those organizations.  Care plan oversight may only be billed by one physician in a month.  

In order to bill for the service, a minimum of 30 minutes of CPO in a calendar month must be billed.  When the claim form is submitted, it must be billed with the start and end date of the month, as the dates of service.

Pay attention to the services that may be included in CPO.  

Here is what the CMS manual says may be included in CPO time:

CPO services require complex or multidisciplinary care modalities involving:
•    Regular physician development and/or revision of care plans;
•    Review of subsequent reports of patient status;
•    Review of related laboratory and other studies;
•    Communication with other health professionals not employed in the same
    practice who are involved in the patient’s care;
•    Integration of new information into the medical treatment plan; and/or  
•    Adjustment of medical therapy.  

A physician may not include these activities in time counted as CPO:

From the CMS manual:

Services not countable toward the 30 minutes threshold that must be provided in order to bill for CPO include, but are not limited to:
•    Time associated with discussions with the patient, his or her family or friends to adjust medication or treatment;
•    Time spent by staff getting or filing charts;  
•    Travel time; and/or  
•    Physician’s time spent telephoning prescriptions into the pharmacist unless the telephone conversation involves discussions of pharmaceutical therapies.

###

Questions, comments?

If you have questions or comments about this article please contact us.  Comments that provide additional related information may be added here by our Editors.

Latest articles:  (any category)