Medicare Reimburses Physicians for Home Health Oversight
Care Plan Oversight Reimbursement
Care Plan Oversight (CPO) is physician supervision of patients under either the home health benefit where the patient requires complex or multi-disciplinary care modalities requiring ongoing physician involvement.
Conditions of Coverage
- The beneficiary must require complex or multi-disciplinary care modalities
- The beneficiary must be receiving Medicare covered home health or hospice services during the period in which the care plan oversight services are furnished;
- The physician who bills CPO must be the same physician who signed the home health plan of care and personally furnishes the care plan oversight services;
- The physician must furnish at least 30 minutes of care plan oversight (see details of countable services below) within the calendar month for which payment is claimed;
- The physician must have provided a covered physician service that required a face-to-face encounter with the beneficiary within the 6 months immediately preceding the provision of the first care plan oversight service (a face-to-face encounter does not include EKG, lab services or surgery);
- The care plan oversight billed must not be routine post-operative care provided in the global surgical period of a surgical procedure billed by the physician;
- For beneficiaries receiving Medicare covered home health services, the physician must not have a significant financial or contractual interest in the home health agency as defined in 42 CFR 424.22 (d);
- Services provided “incident to” a physician’s service do not qualify as CPO and do not count toward the 30-minute requirement.
- The physician billing for Care Plan Oversight must document in the patient’s record the services that were furnished and the date and length of time associated with those services.
The following activities rendered by a physician are countable services toward the 30-minute minimum requirement for care plan oversight:
- Development and/or revision of care plans
- Review reports and patient status
- Review labs and other studies
- Communication with health professionals (not employed in the same practice)
- Participation in Team Conference
- Add new information to care plan
- Reviewing/Signing orders from previous month
- Adjustment of medical therapy
NOTE: The above services are only “countable” if performed by the physician providing the CPO.
The following activities are services not countable toward the 30-minute minimum requirement:
- Services furnished by nurse practitioners, physician assistants, and other non-physicians
- The physician’s telephone call to patient, family or other responsible party
- Phone calls for prescriptions
- Travel time, time spent preparing claims and for claims processing.
- Initial interpretation or review of lab or study results that were ordered during or associated with a face-to-face encounter.
- Low intensity services included as part of other Evaluation and Management services.
- Informal consults with health professionals not involved in the patient’s care.
- The physician’s time spent on discussions with the nurse or therapist, at their own office or with the Home Health Agency staff.
- The work included in hospital discharge day management (99238-99239) and discharge from observation (99217).
Documentation & Billing Tips
- Support need for ongoing complex medical management including integration of new information and adjustments to therapy
- Have more than just the signed treatment plan
- Services Furnished, Dates and Times, and Physician Signatures
- Actual signature (not stamp) required for CMS Form 485 or equivalent
- A copy of signed Plan of Care
- Billing Codes to Use
G0179 Re-certification (once every 60 days after initial Certification)
For more information on Care Plan Oversight,