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Neurosurgery Coding Alert

Stop Forfeiting Your CPO Payments

Published on Tue Feb 10, 2004

Careful documentation could earn you an extra $80

Don't let carriers undervalue your physician's care plan oversight (CPO) services: Start getting paid for CPO with a solid understanding of how and when to report 99374-99380 and G0179-G0182.

Don't Give the Surgeon's Time Away

Suppose the surgeon spends 40 minutes setting up a home health plan of care for a spinal surgery patient who falls during her recovery and sprains her left foot and wrist. Because the patient also has vertigo, the potential for another fall is significant, so your physician prescribes home healthcare and creates goals for the patient's progress. You write off the 40 minutes as nonbillable time - and in the process, you forfeit about $80 in care plan oversight services.

"Reimbursement is quite good for care plan oversight," says Marcella Bucknam, CPC, HIM program coordinator at Clarkson College in Omaha, Neb. "You shouldn't be giving your time away." Although insurers sometimes require preauthorization for CPO services, many payers will recognize such claims.

You Don't Need Face-to-Face Time

CPO services are time-based, non-face-to-face E/M services that include many tasks physicians regularly perform for the long-term management of home health agency, hospice or nursing facility patients under their care (see sidebar for a list of CPO codes, definitions and included services).

Take note: Even though face-to-face time is not required for CPO, a physician billing CPO must have had a face-to-face encounter with the patient within at least six months prior to reporting a CPO claim. Qualifying E/M services include 99221-99263 and 99281-99357. Lab, surgical and electrocardiogram services are not sufficient face-to-face encounters to qualify for CPO.

Know When You Can Report CPO During Global

Suppose Dr. Jones performs surgery on a patient and decides that the patient requires a month of home healthcare during recovery. To determine whether you can report Dr. Jones' services with a CPO code, you have to decide whether the patient requires healthcare because of the surgery.

Section 15513 of the Medicare Carriers Manual (MCM) states that CPO services are only payable if the service was "not routine postoperative care provided in the global surgical period of a surgical procedure billed by the physician."

"If the patient only requires home healthcare because he's recovering from surgery, then the CPO is included in the global surgical package," says Quinten A. Buechner, MS, MDiv, CPC, CHCO, president of ProActive Consultants, a healthcare reimbursement consulting firm in Cumberland, Wis.

For example, if a surgeon performs spinal surgery with instrumentation and requests that a home health practitioner visit the patient weekly to check for infection and help the patient perform range-of-motion exercises, the surgeon cannot report the CPO codes.

Don't Include Travel Time or NPP Services

You cannot report all physician services as CPO, even if they involve considerable time and effort. "Not everything that we think might be countable is countable," says Barbara J. Cobuzzi, MBA, CPC, CPC-H, CHBME, president of Cash Flow Solutions Inc., a reimbursement consulting firm recently relocated to Brick, N.J. "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."

According to the MCM, section 15513, other services not a part of CPO include:

  • initial interpretation or review of lab/study results by the physician 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
  • any routine postoperative care the physician provides during the global surgical period of a procedure.

    Document Thoroughly and Consistently

    As with other time-based codes, 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 own records for each patient: CMS regulations prohibit physicians from using documentation supplied by home health agencies or hospices in lieu of their own documentation.

    "Consistency is the key here," Bucknam says. "Tracking CPO services can be a chore. But by coming up with a system to keep tabs on time, you can reduce the effort considerably. You're spending the time now documenting the services, so you might as well be paid for it."

    Use a Spreadsheet to Ease Record Keeping

    For each patient receiving CPO, Bucknam uses a spreadsheet that becomes part of the patient's record. She labels each spreadsheet with the patient's name and includes columns to record the date, time in/time out and a description of services performed. Whenever the physician performs an activity relevant to CPO, he 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 need not list each date the physician provided CPO services (although you should be able to provide this information upon request). CMS guidelines say 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.

    Payers will reimburse only one unit of CPO service per month (in other words, you cannot bill multiple units of 99374-99380 or G0719-G0182), and only one physician per month can receive payment for CPO services for a specific patient. Specifically, 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.

    Be sure to begin a new spreadsheet each month. "Remember," Bucknam 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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