Check out these 13 musts for billing physician care plan oversight of home care patients.
Don't let the HHS Office of Inspector General scare your referring physicians away from billing for home health patients' care plan oversight.
You can educate docs now on how to bill correctly for CPO, therefore avoiding the OIG's censure. Physicians must perform at least 30 minutes of CPO-eligible services per patient, per month to correctly claim the service (HCPCS codes G0181, G0182).
On the other hand, except in rare cases, physicians generally must only sign the plan of care to bill correctly for certification and recert services (codes G0179, G0180).
Here are 13 criteria the OIG says CPO services must meet, giving physicians the green light to bill: 1. The physician furnished at least 30 minutes of CPO services within the calendar month for which payment is claimed;
2. The beneficiary to whom the services are furnished was receiving Medicare-covered HHA or hospice services during the period in which the CPO services were furnished;
3. The physician who bills CPO services must be the same physician who signed the HHA or hospice plan of care;
4. The CPO services are personally furnished by the physician who bills them;
5. The work included in a hospital discharge day (management and discharge from observation) is not countable toward the 30 minutes per month. On the same day as discharge, only those services separately documented as occurring after the patient is actually physically discharged from the hospital count;
6. The physician provided a covered physician service that required a face-to-face encounter with the beneficiary within the six months immediately preceding the provision of the first CPO service;
7. The physician billing for CPO services must document in the patient's record what services were furnished and the date and length of time associated with those services. "Documentation supplied by HHA or hospices may not be used in lieu of a physician's documentation," the OIG instructs;
8. If the beneficiary is receiving HHA services, the physician did not have a significant financial or contractual interest in the HHA;
9. The physician is not billing for Medicare end stage renal dialysis (ESRD) capitation payment for the same beneficiary during the same month;
10. The beneficiary required complex or multi-disciplinary care modalities requiring ongoing physician involvement in the patient's plan of care;
12. The CPO billed by the physician was not routine post-operative care provided in the global surgical period of a surgical procedure billed by the physician; and
13. Services provided incident to a physician's service do not qualify as CPO and do not count toward the 30-minute requirement.
Source: October 2003 OIG report "Review of Medicare Care Plan Oversight In Puerto Rico" (A-02-02-01019),
http://oig.hhs.gov/oas/reports/region2/20201019.htm.
