Home Health & Hospice Week

Contact docs now to let them in on a new way to make money.

It's final: Physician practices can bill for care plan oversight provided by non-physician practitioners. And that means it's time for you to fire up your marketing machine.

Out with the old: The Centers for Medicare & Medicaid Services has eliminated the provision limiting CPO billing to the physician who certified or recertified the plan of care for the home care patient.

In with the new: That means non-physician practitioners - nurse practitioners and clinical nurse specialists - now can bill for the service. Physician assistants can perform the service, but cannot independently bill for it, CMS notes in the final physician fee schedule slated for publication in the Nov. 15 Federal Register.

Back in 2000 CMS opened up CPO billing to NPPs, but the certification requirement had kept NPPs from being able to bill, a CMS official explained in the Nov. 9 Open Door Forum for home care providers.

This is a positive development for home health agencies and physicians, says Claudia Reingruber of Reingruber & Co. in St. Petersburg, FL.

More physician practices are likely to bill for CPO under the relaxed rules, predicts clinical consultant Judy Adams with LarsonAllen Health Care Group in Charlotte, NC. Nurses may be more willing and able than docs to keep exact records of the time they spend on CPO services, thus facilitating billing, Reingruber notes.

The change promotes better physician service to home care patients and could encourage physicians to refer patients to home care more often.

HHAs can increase their benefit by using the new information in their marketing programs, advises Mike Ferris of Home Care Marketing Solutions in Chapel Hill, NC. Agencies can get valuable face time with physicians and their staff, gain trust and win referrals by passing along the information.

If agencies advised docs of the change when it was proposed in August, now is the time to follow up with the final information, Ferris advises. "The goal is to be the trusted resource for Medicare home care information," he reminds HHAs.

If providers haven't yet contacted physicians on this topic, "there is no time like the present," Ferris urges.

Ferris recommends furnishing the information to practices in a summarized, user-friendly format. If HHAs just hand physicians the lengthy and technical reg, "they have not maximized the opportunity to service the account and show responsiveness," he warns.

Agencies should have a copy of the regulation as a back-up in case the referral source would like to see it, Ferris adds.

Watch out: All is not rosy in the area of CPO, however. The HHS Office of Inspector General has targeted CPO as an area for scrutiny (see Eli's HCW, Vol. XIII, No. 37, p. 290) and physicians report having trouble billing for the service with some carriers, Adams notes.

Difficulty receiving reimbursement may cancel out coverage expansion, Adams cautions.

Remaining question: Meanwhile, the National Association for Home Care & Hospice has a lingering question about the CPO change, NAHC's Mary St. Pierre said in the forum. Now that NPPs can bill for CPO, can a physician who did not certify the patient's plan of care bill for the service as well?

Often the patient's needs change and while one physician signs the POC, another follows the patient at home, St. Pierre explained. 

Editor's Note: The physician fee schedule is at www.cms.hhs.gov/regulations/pfs/2005/1429fc/master_ background_1429-fc.pdf. The CPO portions, including billing requirements, are on pp. 604-608 and pp. 815-817.