Internal Medicine Coding Alert

Face-to-Face Not Required for CPO

Care plan oversight (CPO) services are time-based, non-face-to-face E/M services that include many tasks that internists regularly perform for the long-term management of home health agency, hospice, or nursing facility patients under their care.

Although preauthorization is sometimes required, most payers will recognize these codes. Remember that Medicare only accepts G0179-G0182 for CPO, while private ayers usually require codes from the 99374-99380 series for home health, hospice or nursing facility patients. If you perform CPO for a home, domiciliary or rest home patient who has non-Medicare insurance, use a code from the 99339-99340 series.

Remember: When the physician performs his monthly review of the home healthcare plan, you should not report G0180, because this code applies only to the certification. Instead, for monthly care, report G0181 (Physician supervision of a patient receiving Medicare-covered services provided by a participating home health agency [patient not present] requiring complex and multidisciplinary care modalities involving regular physician development and/or revision of care plans, review of subsequent reports of patient status, review of laboratory and other studies, communication [including telephone calls] with other healthcare professionals involved in the patient's care, integration of new information into the medical treatment plan and/or adjustment of medical therapy, within a calendar month, 30 minutes or more).
 
Spend at Least 30 Minutes on CPO

The internist must spend at least 30 minutes performing CPO before you can report these services. If your practice frequently reports CPO, you should consider stapling a time documentation sheet to the forms that your home health agencies send to you. This form allows the physician to document the time that he spends on the patient's PO.

Practitioners who use CPO codes should keep not only documentation of the time they spend performing the services but also details about what transpired with each contact. Without this documentation, it may be difficult to defend the complexity and time required to manage the patient.
 
Challenge Frequency Limitations

Some internal medicine practices find that Medicare carriers limit coverage for the physician's services performing monthly hospice CPO, for which they report G0182 (Physician supervision of a patient under a Medicare-approved hospice [patient not present] requiring complex and multidisciplinary care modalities involving regular physician development and/or revision of care plans, review of subsequent reports of patient status, review of laboratory and other studies, communication [including telephone calls] with other healthcare professionals involved in the patient's care, integration of new information into the medical treatment plan and/or adjustment of medical therapy, within a calendar month, 30 minutes or more).

"We find that insurers will reimburse for the first two submissions of G0182," says Peggy Lore, coder at Franklin Medical Group in Franklin, Penn. "However, coverage is apparently intended for care up to six months only."

Keep in mind: Some carriers have very specific requirements to maintain billing CPO after six months. For example, Empire Medicare's policy states, "Documentation of an E/M visit within six months of each Care Plan Oversight service must be maintained by the provider in the patient's medical record or in the appropriate in-patient medical record."

Other payers don't outline any frequency requirements in their policies, so if your physician follows the rules but still faces denials, be prepared to appeal. (To review Medicare policies, visit www.cms.hhs.gov/mcd and enter your search terms or your carrier's information.)

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