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Neurology & Pain Management Coding Alert

Stop Overlooking CPO and Boost Your Bottom Line

Published on Tue Oct 01, 2002

Physicians supervising complex and multispecialty patient care can often recoup payment for their time by accessing care plan oversight (CPO) codes 99374-99380. Documentation is crucial when reporting 99374-99380, however, and lack of thorough and efficient records can lead to even more unpaid effort.

What It Is

CPO services are time-based, non-face-to-face E/M codes that include many tasks physicians regularly perform for the long-term management of home health agency, hospice or nursing facility patients under their care. Neurologists might provide such services for management of complex nursing home patients.

"Reimbursement is quite good for these codes," says Shirley Fullerton, CPC, CPC-H, CMBS, academic director of the Medical Association of Billers. "You shouldn't be giving your time away. You should be billing for these services." Although preauthorization is sometimes required (check with your individual insurer), many payers will recognize these codes. The CPT descriptors for CPO (revised for 2002) summarize many of the services included:

  • 99374 Physician supervision of a patient under care of home health agency (patient not present) in home, domiciliary or equivalent environment (e.g., Alzheimer's facility) 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 related laboratory and other studies, communication (including telephone calls) for purposes of assessment or care decision with healthcare professional(s), family member(s), surrogate decision maker(s) (e.g., legal guardian) and/or key caregiver(s) involved in patient's care, integration of new information into the medical treatment plan and/or adjustment of medical therapy, within a calendar month; 15-29 minutes

  • 99375 30 minutes or more

  • 99377 Physician supervision of a hospice patient ; 15-29 minutes
  • 99378 30 minutes or more
  • 99379 Physician supervision of a nursing facility patient ; 15-29 minutes
  • 99380 30 minutes or more.

    Other activities that may be counted toward CPO but that are not specifically mentioned in the CPT descriptors include time devoted to medical decision-making, coordination of services to be performed by the physician (if the coordination of activities requires physician skill) and documenting services provided (e.g., documenting time and decision-making).

    ...And What It Isn't

    You cannot report all physician services as CPO, however, even if they involve significant time and effort. "Not everything that we think should be countable is countable," Fullerton warns. "You cannot count what does not require a physician to perform. The activities must require a physician's skill, and anything that does not meaningfully contribute to the treatment of the illness or the injury does not count."

    Per the Medicare Carriers Manual (MCM), section 15513, other service not included in CPO include:

  • initial interpretation or review of lab/study results ordered during or associated with a face-to-face encounter (these are included as part of the specific encounter)
  • physician phone calls to the patient or family
  • travel time
  • time spent preparing claims for processing
  • low-level services included in a separately reported E/M service (e.g., hospital discharge management 99238 and 99239, or discharge from observation 99217)
  • informal consults or conversations with other healthcare professionals
  • routine postoperative care provided in the global surgical period of a procedure
  • any services that do not require physician skill, such as phoning in prescriptions (unless the conversation involves discussions of pharmaceutical therapies), filing charts or dialing phones, as well as any services not directly provided by the physician, such as time spent by a nurse, physician's assistant or other staff on patient care or any "incident-to" services.

    Note: The latter condition applies chiefly to Medicare. Private payers will sometimes allow CPO to be billed with some incident-to services. Check with your payer.

    Note that a physician billing CPO must have had a face-to-face encounter with the patient for whom the services are reported within the six months immediately preceding the first reported CPO claim. Qualifying E/M services include 99221-99263 and 99281-99357. Lab, surgical and electrocardiogram (EKG) services are not sufficient face-to-face encounters to qualify for CPO.

    Document Thoroughly and Consistently

    You must document CPO services carefully, and physicians must maintain notes to demonstrate that all of the requirements for billing a given CPO code are met, including notations in medical records of the duration of telephone calls. And each physician must keep his or her own records for each patient. CMS regulations prohibit physicians to use documentation supplied by home health agencies or hospices.

    "Consistency is the key," advises Marcella Bucknam, CPC, HIM program coordinator at Clarkson College in Omaha, Neb. "The tracking of CPO services can be a chore. But by coming up with a system, you can reduce the effort considerably."

    "A lot of physicians feel it is not worth their time to track these services. But it is," Fullerton agrees. "You are spending the time now documenting the services, so you might as well be paid for it."

    Bucknam uses a spreadsheet for each patient receiving CPO, which becomes part of the patient's record. She labels each spreadsheet with the patient's name, and includes columns to record date, time in/time out and a description of services performed. Whenever the physician performs an activity relevant to CPO, he or she adds the required information to the spreadsheet for that patient. At the end of each month the billing department or other staff totals the time spent and files claims accordingly.

    When filing the claim, you needn't list each date the physician provided CPO services (although this information should be available upon request). Per CMS guidelines, providers billing for CPO must submit the claim with no other services billed on that claim, and may bill only after the end of the month in which the CPO services were rendered. Only one unit of service will be reimbursed per month (i.e., you cannot bill multiple units of 99374-99380). Only one physician per month can receive payment for CPO services for a specific patient: The physician who signed the plan of care for the home health agency or hospice is the physician who bills the care plan oversight service.

    In addition, be sure to begin a new spreadsheet each month. "Remember," Fullerton says, "the time is based on a calendar month. This is important: You cannot combine a week from last month with the first two weeks of this month to arrive at the desired billable time."

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