Part B Insider (Multispecialty) Coding Alert

30-minute requirement doesn't apply to these codes

When the HHS Office of Inspector General urged the Part B carriers to crack down on physicians billing for home health care plan oversight (CPO), it may have caused a panic (See PBI, Vol. 6, No. 27).
 
Billing for home health CPO (G0181) or hospice CPO (G0182) can be tricky, because the physician has to prove he or she spent at least 30 minutes within a calendar month overseeing a home health patient's care.

Good news: But you don't need to document time spent to bill for certifying (G0180) or recertifying (G0179) a home health patients' plan of care, say experts. And you can bill for G0179 or G0180 every 60 days, either with or without G0181. If your physician is already ordering home health for some patients, then you should go ahead and bill for the work your doctor is doing, they add.

Many physicians don't realize they can bill for this service, experts say. They offer these tips:

  Keep a copy of the certification. "Physicians certainly have to prove that they actually certified/ recertified patients," advises Burtonsville, MD-based health care attorney Elizabeth Hogue. "They should do that by keeping a copy of each [cert] in patients' records."

  Extra documentation helps. Medicare doesn't have any specific documentation requirements for cert and recert, according to the American Academy of Home Care Physicians, but the OIG has called on physicians to document these services in detail.  "Some providers ... dictate/write a brief note outlining the activities performed related to (re)certification," notes Dr. Edward Ratner, medical director for Heartland Home Health Care and Hospice in Minneapolis.

  Don't count the same activities toward cert/recert as well as CPO. "The work and time spent developing the plan of care for the certification must be separate and apart from the time counted toward care plan oversight," Part B carrier TrailBlazer Health Enterprises says in its local coverage determination on cert/recert.

TrailBlazer requires physicians to be actively involved in supervising home health and to have seen the patient within the past six months, unless unusual circumstances make such activities impossible.