Gastroenterology Coding Alert

CPO Coding:

Keep Documentation Airtight When Reporting CPO Services

Published on Wed May 24, 2023

Hint: Don’t forget to append modifier GV.

Gastroenterologists commonly perform home health services, but less commonly bill for them correctly. This may come from not knowing how to code the encounters and what documentation is required to ensure fair reimbursement.

Part of that process includes care plan oversight (CPO). Here, we’ll offer a breakdown of CPO codes, how to report them correctly — and how to get the pay your deserve.

Know the Basic Steps for Correctly Reporting CPO

Once it’s officially established that the patient is eligible for home care, and there is a home care plan in place, the process for documenting CPO is essentially as follows:

1. Document the provider’s supervision of the patient’s care, reviewing reports, adjusting the plan as needed, and communicating with the home health or hospice staff.

2. Thoroughly document the time spent on CPO activities, ensuring that at least 30 minutes per calendar month are accounted for.

3. Report the appropriate codes, based on the payer requirements.

4. Append Modifier GV (Attending physician not employed or paid under arrangement by the patient’s hospice provider) to show the payer that hospice is not also trying to bill for the same service(s).

Note: Non-physician practitioners (NPPs) are also eligible to bill for CPO services as of March 2020. Although this was a change sparked by the COVID-19 public health emergency (PHE) it was created to be a permanent change. This was “a big change for home health,” says to Joe Osentoski with Gateway Home Health Coding & Consulting in Madison Heights, Michigan. However, the provider who bills CPO must be the same one who signed the plan of care.

Review the Codes

CPO refresh: According to the Centers for Medicare & Medicaid Services (CMS), CPO is “supervision of patients under the care of home health agencies or hospices that require complex and multidisciplinary care modalities involving regular physician development and/or revision of care plans. …” These patients sometimes require care outside of the home health agency or hospice-provided services (Source: www.cms. gov/Regulations-and-Guidance/Guidance/Manuals/downloads/ bp102c15.pdf).

Medicare CPO codes:

G0179 (Physician or allowed practitioner re-certification for Medicare-covered home health services under a home health plan of care (patient not present), including contacts with home health agency and review of reports of patient status required by physicians and allowed practitioners to affirm the initial implementation of the plan of care)
G0180 (Physician or allowed practitioner certification … review of reports of patient status ... to affirm the initial implementation of the plan of care ...)
G0181 (Physician supervision of a patient receiving Medicare-covered services provided by a participating home health agency ...)
G0182 (Physician supervision of a patient under a Medicare-approved hospice (patient not present) requiring complex and multidisciplinary care modalities...)

Private payer codes:

99374 (Supervision of a patient under care of home health agency (patient not present) in home, domiciliary or equivalent environment (eg, Alzheimer’s facility) requiring complex and multidisciplinary care modalities involving regular development and/or revision of care plans by that individual, review of subsequent reports of patient status, review of related laboratory and other studies, communication (including telephone calls) for purposes of assessment or care decisions with health care professional(s), family member(s), surrogate decision maker(s) (eg, legal guardian) and/or key caregiver(s) involved in patient’s care, integration of new information into the medical treatment plan and/or adjustment of medical therapy, within a calendar month; 15-29 minutes)
99375 (… 30 minutes or more)
99377 (Supervision of a hospice patient …; 15-29 minutes)
99388 (… 30 minutes or more)

Note: Although preauthorization is sometimes required, many payers will recognize these codes.

Rely on Documentation to Support CPO Codes

As long as the documentation is airtight, there should be no trouble getting paid provided you meet Medicare requirements. For one, the provider must spend at least 30 minutes performing face-to-face CPO services within a calendar month in order for you to report G0181 or G0182 to Medicare. Time spent preparing and consulting with the nurse does not count toward that time as it does for a standard outpatient E/M service.

Similar to the documentation required to support a standard time-based E/M service, the provider must fully document the services performed during those visits, including the date and time spent to support Medicare’s face-to-face time requirements.

For private payers, keep Medicare’s requirements in mind and document as much information as possible to back up each service. Think about how you’ll be documenting each encounter as meticulously as you would to justify a high-level, time-based E/M service. Check with each private payer’s policy to see if there are any CPO-specific documentation requirements.

Note: Medicare does not consider time spent establishing the home health plan as billable. However, you can report this time with a corresponding outpatient E/M code, such as 99202-99215 (Office or other outpatient visit for the evaluation and management of a/an new/established patient, which requires a medically appropriate history and/or examination…)

Identify Opportunities to Report CPO During Global Periods

As you know, payers aren’t likely to pay CPO services if a patient needs only routine post-operative care after surgery because the global package already includes these services.

In addition, Section 180 of the Medicare Claims Processing Manual states that physicians cannot count the following activities toward the CPO time:

Discussions with the patient, his family, or his friends adjusting medications or treatment;
Staff time getting or filing charts;
Travel time; or
Phoning in prescriptions (unless the phone conversation involves discussion of pharmaceutical therapies).

Because of this, finding ways to properly bill for CPO services after surgery can seem tricky. However, the following scenario will help you understand when billing for CPO aftercare is appropriate.

Example: The gastroenterologist consulted on a surgery patient and based on previously documented patient limitations, decides that patient requires a month of home care during recovery. Part of that home care includes providing orders for and supervising total parenteral nutrition (TPN), which is an intravenous method of feeding that bypasses the gastrointestinal tract.TPN is not routine postoperative care, and therefore not a service that’s bundled within the global period for the surgeon.

The gastroenterologist should document a detailed account of the services required, as well as any applicable medical records that include diagnoses, functional limitations, and the medical necessity for home care during the recovery period. Then, once a care plan is established, the provider can progress through the home care services feeling confident to receive proper reimbursement using the CPO codes throughout the patient’s recovery.

Modifier alert: Remember to append modifier GV to show the payer that the provider is not employed by a hospice. Many private payers will also accept this modifier, but as always, check with the payer for details.

For a complete list of processes and requirements, check out Chapters 12 and 15 of the Medicare Benefit Policy Manual: (https://www.cms.gov/Regulations-and-Guidance/Guidance/ Manuals/Downloads/clm104c12.pdf), (https://www.cms.gov/ Regulations-and-Guidance/Guidance/Manuals/downloads/ bp102c15.pdf).Or, check with your Medicare Administrative Contractor (MAC) for instructions on how to submit a CPO claim.