Practice Management Alert

Question: What are the rules when it comes to billing for care plan oversight for a home health patient?

Answer: Physicians can use CPT codes G0064-G0066 to bill for care plan oversight activities, but you have to make sure your coding is accurate to avoid denials.

CPO activities include "regular physician development and/or revision of care plans, review of subsequent reports of patient status, review of related laboratory and other studies, communication with other health professionals not employed in the same practice who are involved in the patient's care, integration of new information into the medical treatment plan, and/or adjustment of medical therapy," according to the Medicare Carrier's Manual.

Further, to bill for CPO the physician must document that she devoted at least 30 minutes to these activities during the month for which the payment is claimed. That means before billing for the activity, the doctor must clearly document in the patient's record which services he performed, along with the date and the amount of time he devoted to those services.

And only the physician's time counts toward that 30-minute threshold, not a nurse's time. Other activities that don't count toward CPO are as follows: time associated with discussing with the patient (or her family/friends) medication or treatment adjustments, time staff spends retrieving or filing charts, travel time, and time spent phoning prescriptions in to a pharmacist (unless the conversation involves discussions of pharmaceutical therapies).

A physician also isn't allowed to simply sign off on notes made by a non-physician and then bill for CPO. This is an important point to remember, because many home health agencies will offer to take care of a physician's CPO duties for him. The Centers for Medicare & Medicaid Services is very clear in its denunciation of this strategy, though. The carrier's manual clearly states, "Documentation supplied by home health agencies or hospices may not be used in lieu of a physician's documentation.

"In addition to the G codes, physicians can bill 99374 for 15 to 29 minutes for supervision of a patient "under care of home health agency (patient not present) in home, domiciliary or equivalent environment," CPT 2003 states. Codes 99377 and 99379 apply to equivalent supervision for patients in under the care of a hospice or nursing facility, respectively. If the physician's documentation shows that he has devoted 30 minutes or more within the calendar month to supervision activities for patients in home health, hospice, or nursing facility care, you can bill codes 99375, 99378, and 99379, respectively.