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Oncology & Hematology Coding Alert

10 Easy Dos and Donts of CPO Billing

Published on Sun Sep 01, 2002

The effort that goes into Care Plan Oversight might seem mountainous, but it's worth the trouble for oncologists who work with hospice patients to get their documentation ducks in a row.

Care Plan Oversight (CPO) services are reported separately from other physician services provided in the hospital, office, home, nursing facility or hospice. CPO runs according to a 30-day clock and exists "to reflect that physician's sole or predominant supervisory role with a particular patient," according to CPT 2002. For the first 15-29 minutes of supervisory services, charge 99374 (Physician supervision of a patient under care of home health agency [patient not present] in home, domiciliary or equivalent environment ; 15-29 minutes), and for a nursing facility patient use 99379 (Physician supervision of a nursing facility patient [patient not present] requiring complex and multidisciplinary care modalities ; 15-29 minutes).

Oncology practices are likely to see a lot more of 99374, which covers patients under the care of a home health agency, says Elaine Towle, CMPE, practice administrator for New Hampshire Oncology and Hematology in Hooksett. Oncology patients frequently use home health services as an interim step to hospice care.

For supervision services that run 30 minutes or longer, use 99375, 99378 or 99380, depending on the facility setting.

Remember that the billing for these services may include only those services provided by the physician, not by her staff. For example, Towle says, the time a nurse spends on the phone trying to reach family members or giving care instruction cannot be counted under these codes. When determining how to bill for CPO, consider this list of do's and don'ts:

  • Do make sure the patient is receiving complex care requiring ongoing physician involvement.
  • Do ascertain that the patient is receiving Medicare-covered services (home health agency, hospice, or nursing facility) during the CPO period.
  • Do provide at least 30 minutes of CPO for every calendar month for which you claim CPO payment.
  • Do make sure that the physician who bills for the CPO services is the same person who furnished them.
  • Do document in the patient record which services were furnished, as well as the date and length of time of the services.
  • Don't bill CPO for routine postoperative care provided in the global surgical period.
  • Don't bill for Medicare-covered hospice services if the physician is a medical director or employee of the hospice.
  • Don't bill for Medicare-covered hospice services if the physician has a significant financial or contractual interest in the home health service.
  • Don't bill for services provided "incident-to" a physician's service.
  • Don't bill CPO during the same calendar month in which the physician bills the Medicare monthly capitation payment for the same patient.

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