Home Health & Hospice Week

Medicare to allow non-physician practitioners to bill for care plan oversight.

If you're looking for a good reason to get in touch with your physician referral sources, here it is - changes to care plan oversight rules that could bring more dollars to physician practices.

The Centers for Medicare & Medicaid Services admits it made a mistake in structuring home health and hospice care plan oversight rules with respect to non-physician practitioners, according to the proposed 2005 physician fee schedule.

The problem: "Our policy has been that the physician who bills for CPO must be the same physician who signs the plan of care and ... only a physician can sign the plan of care for home health services," CMS explains in an Aug. 5 Federal Register notice. These opposing requirements "created a problem with respect to an NPP billing for CPO in the home health setting."

The solution: CMS proposes allowing NPPs (nurse practitioners, clinical nurse specialists or physician assistants) to "perform home health CPO [G0181 and G0182] even though they cannot certify a patient for home health services and sign the plan of care." But it's not quite that simple - the NPPs will have to meet a list of requirements to qualify for payment (see box, next page).

This significant change allows physician practices "the possibility to bill for more patients under CPO" and thus increase their Medicare reimbursement, notes Mike Ferris of Home Care Marketing Solu-tions in Chapel Hill, NC.

And that makes right now the perfect time to get in touch with your physician referral sources to tell them all about the money-making opportunity. "Any change to the Medicare home health program represents a marketing opportunity," Ferris advises. "Since successful home health sales involves building a relationship with the physician practices, any time that the HHA can provide timely information they are building that stronger relationship."

The CPO billing changes will be especially useful if you've already marketed to practices on CPO billing, Ferris notes. Laying the groundwork with previous education gives you easier accessibility for a followup.

Tip: Smart HHA marketers will keep careful records of which referral sources they have contacted with what information. Then when a change occurs like this one, you can look up anyone you've contacted with CPO information and follow up with them on the new developments, Ferris counsels.

Who to target: Office and billing managers, who will quickly grasp the difference the change can make to the practice's bottom line, will be the most receptive audience to this information, Ferris recommends.

But don't let practice employees steal all the credit for bringing up the change with physicians. "You can make them look like heroes and not get an additional referral out of it," Ferris warns.

Keep in mind when marketing that the CPO changes are still in proposed form, but are widely expected to go into place Jan. 1. CMS will take comments on the proposal until Sept. 24. 

Editor's Note: The proposed fee schedule is at www.access.gpo.gov/su_docs/fedreg/a040805c.html.