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Oncology & Hematology Coding Alert

Reader Question:

Care Plan Oversight

Published on Wed May 01, 2002

Question: Our physicians are beginning to bill Medicare for care plan oversight (CPO). What are the necessary requirements for billing?

Vermont Subscriber

Answer: In 2001, Medicare implemented the following codes for CPO of patients under the care of a home health agency or hospice: 99374 and 99375 for home health, and 99377 and 99378 for hospice.

The codes are time-based. A physician may report any one of the above codes after he or she has accrued the 30 minutes of CPO of a patient's care with the home health agency or hospice personnel.

Medicare carriers will vary, but most follow these guidelines:

  • The beneficiary must require complex or multidisciplinary care modalities requiring ongoing physician involvement in the patient's plan of care.
  • The beneficiary must be receiving Medicare-covered home health agency (HHA), hospice, or nursing facility services during the period in which the CPO services are furnished.
  • The physician who bills CPO must be the same physician who signed the home health or hospice plan of care.
  • The physician must furnish at least 30 minutes of CPO within the calendar month for which payment is claimed, and no other physician can be paid for CPO within that calendar month.
  • The physician must provide a covered service that requires a face-to-face encounter with the beneficiary within the six months immediately preceding the provision of the first CPO service (a face-to-face service does not include EKG, lab services or surgery).
  • The CPO billed must not be routine postoperative care provided in the global surgical period of a surgical procedure billed by the physician.
  • For beneficiaries receiving Medicare-covered home health services, the physician must not have a significant financial or contractual interest in the home health agency.
  • For beneficiaries receiving Medicare-covered hospice services, the physician must not be the medical director or an employee of the hospice or providing services under arrangements with the hospice.
  • CPO services must be personally furnished by the physician who bills them.
  • Services provided "incident to" a physician's service do not qualify as CPO and do not count toward the 30-minute requirement.
  • The physician may not bill CPO during the same calendar month in which he or she bills the Medicare monthly capitation payment for the same beneficiary.
  • The physician billing for CPO must document in the patient's record which services were furnished and the date and length of time associated with services.

    Answers to You Be the Coder and Reader Questions provided by Elaine Towle, CMPE, practice administrator for New Hampshire Oncology and Hematology in Hooksett; Margaret Hickey, MS, MSN, RN, OCN, CORLN, independent coding consultant in New Orleans; Nancy Cothern, practice administrator, Baptist Cancer Institute, Jacksonville, Fla.; and Cindy Parman, CPC, CPC-H, president and co-founder of Coding Strategies, Dallas, Ga.

     

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