Neurology & Pain Management Coding Alert

Medicare payers do not follow CPT guidelines for care plan oversight (CPO) and will not accept codes 99374-99380. Instead, Medicare designates HCPCS G codes G0181, which corresponds to CPT 99375, and G0182, which is equivalent to CPT 99378. Note that Medicare will not reimburse for CPO for patients in a skilled nursing facility (although it will pay for E/M visits). Also, Medicare will not reimburse for CPO services totaling less than 30 minutes per month because it considers these to be bundled to (i.e., included as part of or incidental to) other billable physician services.

In addition, Medicare requires that physicians certify and after 60 days of treatment recertify all patients receiving CPO services under the care of a home health agency. "This is to encourage continuing physician involvement in the provision of home healthcare," says Shirley Fullerton, CPC, CPC-H, CMBS, academic director of the Medical Association of Billers.

These services must be documented and reported using G0179 (Physician recertification services for Medicare-covered services, provided by a participating home health agency [patient not present] including review of subsequent reports of patient status, review of patient's responses to OASIS assessment instrument, contact with the home health agency to ascertain the follow-up implementation plan of care, and documentation in the patient's office record, per certification period) and G0180 (Physician certification ... including review of initial or subsequent reports ... to ascertain the initial implementation plan of care ...).

To report G0179 and G0180, you should describe in the patient's office record and physician chart the activities involved in deciding whether the home healthcare plan is appropriate or if the proposed care plan needs to be modified to better meet the beneficiary's needs. As a precaution, Fullerton suggests keeping a copy of the approved care plan in the patient's chart.

Physicians must enter on the Medicare claim form the six-character Medicare provider number of the home health association or hospice providing Medicare-covered services to the beneficiary for the period during which CPO services were furnished and for which the physician signed the plan of care. And physicians should provide their personal identification number (PIN) to the home health agency or hospice furnishing services to their patient.

Note: See MCM, section 15513, for all relevant Medicare guidelines for CPO services.