Home Health & Hospice Week

Massive denials could scare docs away from billing underutilized service - and referring to home care.

Convincing physicians to bill for home health care plan oversight may have just gotten harder.

The HHS Office of Inspector General continues its scrutiny of CPO in a report focusing on two Texas physicians' CPO claims in 2001 and 2002. The OIG and Medicare Carrier TrailBlazer Health Enterprises denied 236 out of 239 CPO and home health certification/recertification services billed by the two unnamed Texas docs.

The physicians actually furnished only nine of the 239 services billed, the OIG says in the report. The remaining 230 services were computer glitches or other errors that resulted in multiple units of CPO being billed on one claim.

But of the nine CPO and cert services the docs did furnish, Trailblazer still denied six for lack of supporting documentation, the OIG says. The overall result was nearly $16,000 in overpayments to the physicians.

Ignorance no excuse: One physician said he didn't know about the requirements for documenting CPO supervision services and so didn't properly document the services in the patients' medical records.

Docs: CPO Not Worth the Hassle

The OIG maintains a keen interest in CPO billing because its use has grown exponentially in recent years, notes Burtonsville, MD-based health care attorney Elizabeth Hogue. "Although still relatively small in the whole scheme of things ... growth seems to produce monitoring by regulators," Hogue observes.

The CPO codes G0181 and G0182 aim to reimburse physicians for the time they spend managing their home care patients, if the time is at least 30 minutes per month.

Already many physicians don't bill for CPO because of the hassle of documenting the 30 minutes of services, says Constance Row of the American Academy of Home Care Physicians. An OIG crackdown could lead to an even further "chilling effect" on physician CPO billing, and a corresponding impact on home care referrals, Row predicts.

In addition to the documentation burden, physicians don't bill CPO because they are confused about which services count toward the 30 minutes and which don't, Row continues.

CPO Education Needed

At first glance, this report may seem detrimental to CPO billing, since Trailblazer denied nearly all of the CPO services audited. But physicians should realize that most of the denials were due to possible accidental inflation of the services billed.

The report shows that "CPO codes are fully recognized and supported by the OIG," stresses Dr. Edward Ratner, medical director for Heartland Home Health Care and Hospice in Minneapolis. There's "no need to worry that you will get in trouble simply for using these codes correctly," assures Ratner, past AAHCP president.

The report really underscores the need for more education from carriers on CPO, says Ratner, also an associate professor at the University of Minnesota Medical School. The OIG backs up that point, recommending that Trailblazer educate physicians on billing and documenting CPO.

Home health agencies can ward off knee-jerk reactions against CPO billing by doing some educating of their own, Hogue recommends. "Some education from HHA staff about what caused denials and how to combat them ... should be sufficient" to prevent negative effects, she says.

Cloud on the horizon: Home care providers' biggest fear may be a more general fraud alert about CPO services. Such a broadcast alert could be "chilling" for home care referrals, worries Bob Wardwell with the Visiting Nurse Associations of America.

The OIG has issued fraud alerts on home care topics in the past that have done just that, Wardwell recalls. "Hopefully, they learned something last time and will not try another shock and awe campaign," he says. "It only scares the good docs anyhow." 

Note: The OIG report is at www.oig.hhs.gov/oas/reports/region6/60400083.pdf. Watch for information on physician billing of certification and recertification services in an upcoming issue.