2. Goals and Objectives
Understand The Concept of CPO
Know the difference between CPO and
Certification/Recertification
Make the Information Physician Specific
Sell The Idea to Physicians
Reap The Rewards
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3. Understand The Concept of
CPO, Certification/Recertification
Physician
PLUS
Education
EQUALS
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4. What Codes are Used?
Effective January 1, 2001 HCPCS codes
were added for physician services:
G0180 – Certification HHA patient
G0179 – Recertification HHA patient
G0181 – Home Health Care Plan Oversight
G0182 – Hospice Care Plan Oversight
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5. Understand The Difference
Between CPO and Cert/Recert
What is CPO What is Cert/Recert
How does it work How does it work
How to make it How to make it
work for my work for my
agency agency
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6. What is Certification?
G0180 MD Certification of HHA patient
Certification Billing Requirements
Must be billed by the physician that signed the
patient’s Plan of Care
Used when a patient has not received Medicare
covered home health services for at a least 60 days
Copy of Certification 485 in patient’s chart is sufficient
documentation to support physician billing
Date of service: Date the physician signs the POC
Billed on Form HCFA-1500
Locator 23: HHAs 6-digit Medicare provider number
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7. What is Recertification?
G0179 MD Recertification of HHA patient
Recertification Billing Requirements
Must be billed by the physician that recertified the patient.
Used after a patient has received Medicare covered home health
services for at a least 60 days*
Copy of Recertification 485 in patient’s chart is sufficient
documentation to support physician billing
Date of service: Date the physician signs the POC
Billed on Form HCFA-1500
Locator 23: HHAs 6-digit Medicare provider number
*The G0179 code will 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.
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8. What is CPO?
Care Plan Oversight (CPO) is physician
supervision of patients under either the
home health (G0181) or
hospice (G0182) benefit
the patient requires complex or multi-
disciplinary care modalities requiring
ongoing physician involvement.
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9. Requirements for CPO
The beneficiary must be receiving Medicare
covered home health services during the
period in which care plan oversight services
are furnished.
The physician must have provided a
covered physician service that required a
face to face encounter with the beneficiary
in the 6 months before the first billing for
care plan oversight services.
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10. Requirements for CPO
The beneficiary must require complex or multi-
disciplinary care
•The physician must furnish at least 30
minutes of supervision within the calendar
month for which payment is claimed and no
other physician has been paid for CPO
within that calendar month
The care plan oversight services must be
personally provided by the physician who bills
for the service
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11. Requirements for CPO
Billing for CPO by surgeons must not be routine post-
operative care provided in a global surgical period
Payment will be allowed for care plan oversight to
physicians providing post surgical care during the post
operative period only if the care plan oversight is
documented to be unrelated to the surgery.
The physician must NOT have a significant financial or
contractual interest in the home health agency
The physician is not the medical director or employee of
the hospice, and does not provide services under an
arrangement with the hospice
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12. Requirements for CPO
Services provided incident to office visits do not
count towards the 30 minute requirement
The physician must not bill CPO during the same
calendar month in which he/she bills ESRD benefit
for the same patient
The physician billing CPO must document in the
patient’s record which services were furnished,
the date and length of time associated with those
services (see sample log)
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13. Sample CPO Log for Physician
Patient’s Name ______________________ Agency Name___________________
Physician Signature ________________________________________
Sub- Time
Date (mm/dd/yyyy) total
Development of Care minutes minutes minutes minutes minutes minutes minutes minutes minutes minutes minutes
Revision to Care Plan minutes Minutes minutes minutes minutes minutes minutes minutes minutes minutes minutes
Review of Pt. Records minutes minutes minutes minutes minutes minutes minutes minutes minutes minutes minutes
Lab Reviews minutes minutes minutes minutes minutes minutes minutes minutes minutes minutes minutes
Diag. Test Reviews minutes minutes minutes minutes minutes minutes minutes minutes minutes minutes minutes
Comm w/Health Prof. minutes minutes minutes minutes minutes minutes minutes minutes minutes minutes minutes
Integration of New Info-
Treatment Plan minutes minutes minutes minutes minutes minutes minutes minutes minutes minutes minutes
Adjustment/Med Therapy Minutes minutes minutes minutes minutes minutes minutes minutes minutes minutes minutes
Other (define minutes minutes minutes minutes minutes minutes minutes minutes minutes minutes minutes
Total Time
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14. Requirements for CPO
Physician Documentation
Documentation must be done by the
physician and not by the HHA
An agency’s provision of that service to a
physician could be viewed as a kickback
intended to induce referrals.
Billing must be done by the physician’s
office staff and not by the HHA. (see Filing
a Claim)
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15. CPO and Nurse Practitioners
Under the provisions of the BBA, nurse practitioners,
physician assistants and clinical nurse specialists,
practicing within the scope of State law, can bill for
care plan oversight services.
These non-physician practitioners must have been
providing ongoing care for the patient through
evaluation and management services provided as
a physician service.
If these practitioners are seeing the patient only for
home health/hospice nursing visits, they may not bill
for CPO.
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16. Countable Services
The following services are countable
toward the 30 minute minimum for care
plan oversight
Review of reports, orders, treatment plans,
or lab or study results, except for the initial
interpretation or review of lab or study
results that were ordered during or
associated with a face to face encounter.
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17. Countable Services
Telephone calls with other health care
professionals involved in the care of the
patient
Physician development and/or revision of care
plans
Review of subsequent reports of patient
status
Team conferences (Time spent per individual
patient must be documented)
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18. Countable Services
Medical decision making:
integration of new information into the
medical treatment plan
adjustment of medical therapy
Activities to coordinate services are countable
if the coordination activities require the skills
of a physician
Time spent working on a care plan after the
nurse has conveyed pertinent information to
the physician
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19. Non-Countable Services
Initial interpretation of lab or study
results ordered during a face to face
encounter
Physicians telephone calls to patient,
family or pharmacy, even to adjust
medication or treatment.
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20. Non-Countable Services
Travel time , time spent preparing
claims or for claims processing
Low intensity services included as part
of other evaluation and management
services
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21. Non-Countable Services
Informal consults with health
professionals not involved with the
patient’s care
Time spent discussing the patient
with office staff
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22. Filing a Claim
All claims for CPO must contain the 6 digit
Medicare provider number for the HHA or
hospice rendering covered Medicare services
during the period in which the care planning was
furnished.
FORM 1500
Item 23: Prior authorization number –
HHA 6-digit Medicare provider number
Item 32: Facility where services were furnished –
Physician’s office
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23. Filing a Claim
Dates of service entered on the
claim form must be the first and last
date during which documented care
planning services were actually
provided during the calendar month,
not just the first and last days of the
calendar month in which the claim is
submitted
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24. Filing a Claim
Medical records for those dates must
document that 30 minutes or more of
time have been spent by physicians for
countable care planning activities as
well as which services were furnished
and the date and length of time
associated with those services
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25. Filing a Claim
The physician must bill for no other
services than CPO services on the
claim,must bill care planning only once
per calendar month, must bill only one
month’s services per line item and must
not submit the claim until after the end
of the month in which the service is
performed
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26. Filing a Claim
Beneficiary Liability
CPO is a Medicare Part B benefit
Medicare pays 80% of the fee schedule
amount for physician services
Beneficiary is responsible for 20%
coinsurance --either through supplemental
insurance or out-of-pocket
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27. How do I make it work
for my Agency?
Be willing to invest the time to provide
the education to physician offices
Start with your biggest referring physician
Follow the physicians case load
Compile notes and documentation from a
sample of the physicians patient base
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28. How do I make it work for me?
Prepare an Educational Packet
Track documentation per physician
Prepare spread sheet per physician
Compile a sample month for that physician
on a spreadsheet using his own patients
and numbers
Put together a presentation per physician
that includes brief instruction, his patient’s
documentation and his spread sheet
showing the bottom line
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29. It will work!
Sell the idea to the physicians
Make an appointment to talk directly to the
physician and/or billing staff
Present him with a brief overview of home
care criteria
Present him with the fact that he is able to
bill for home care services and a very brief
outline of how
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30. It will work!
Use Physician’s own numbers in your favor
Provide a sample log for the physician’s
use in documenting time
Offer to instruct staff in billing procedures
Offer to send a current list of patients
every month
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31. Reap the rewards
Increased referrals
Add Up to
Increased profits
For YOU!!
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