1.   What place of service should be used when billing Care Plan Oversight (CPO) services to Medicare?

The provider should use the place of service where the service was rendered, e.g. office, inpatient, nursing home, home, etc.

2.   Can two different physicians with the same specialty within the same group bill for Care Plan Oversight services?

The physician that bills CPO must be the same physician that signed the home health or hospice plan of care. In addition, Medicare will only cover one (1) Care Plan Oversight service per patient per certification/recertification period (G0179 and G0180), or calendar month (G0181 and G0182).

3.   Can two different physicians bill for Care Plan Oversight services (G0181-G0182) and monthly capitation payment procedure codes (G0308-G0327) in the same calendar month for the same beneficiary?

If the physicians are different and have two different provider numbers, then the physician managing the Care Plan Oversight services may bill the Care Plan Oversight procedure codes (G0181 and G0182) and the physician managing the End Stage Renal Disease can bill the monthly capitation payment procedure codes (G0308-G0327) within the same calendar month for the same beneficiary. Please note: The physician that bills CPO must be the same physician that signed the home health or hospice plan of care. Also, the same physician may not bill for both the Care Plan Oversight service procedure codes (G0181 and G0182) and the monthly capitation payment procedure codes (G0308-G0327) in the same calendar month for the same beneficiary.

4.   For countable activities, may a physician use a “log” sheet as appropriate documentation for Care Plan Oversight services?

A log sheet may be appropriate as documentation for Care Plan Oversight services if the appropriate countable services are listed on the log sheet, there is a notation in the documentation as to the total time spent in each countable service performed, and that the log is individualized to the patient for the calendar month that the CPO services were performed.

5.   If the Local Coverage Determination states that “the physician who bills CPO must be the same physician who signed the home health or hospice plan of care,” how can Non-Physician Practitioners (NPP) bill for CPO services (G0181-G0182)?

Nurse practitioners, physician assistants, and clinical nurse specialists, practicing within the scope of state law, may bill for care plan oversight (G0181 and G0182). These non-physician practitioners must be providing ongoing care for the beneficiary through evaluation and management services (but not if they are involved only in the delivery of the Medicare covered home health or hospice service).

Non-physician practitioners may not be reimbursed for the certification/recertification codes (G0179 and G0180) at this time.

6.   Can a physician bill Care Plan Oversight services if the physician has a contract for billing purposes with the hospice agency?

The physician should not bill CPO services if (s)he is an employee of a hospice, which would include a volunteer medical director. Payment for the services of a physician employed by the hospice is included in the payment to the hospice. For beneficiaries receiving home health services, the physician must not have a significant financial or contractual interest in the home health agency (HHA) as defined in 42 CFR 424.22(d).

7.   For procedure codes GO179 and G0180 (Re-certification and Certification), does Medicare require a separate note to be documented by the physician in the medical record in addition to the OASIS form and the 485?

Medicare does not require the physician to submit the OASIS form and/or the 485 form. However, Medicare does require an additional note to be documented by the physician in addition to the OASIS form and the 485 form. Review of any initial and subsequent reports of the patient’s status, review of the OASIS and the status of how the patient is responding to the OASIS instrument, and any contact with the home health agency to ascertain the initial or follow up implementation plan of care should also be documented in the patient’s medical record. Documentation supplied by the home health agency or hospice cannot be used in lieu of the physician documentation.

8.   Why does the physician have to document an additional note when they sign the OASIS and 485 form for procedure codes G0179 and G0180?

Medicare does not require the physician to submit the OASIS form and/or the 485 form. However, procedure codes G0179 and G0180 are specific to what should be documented in the medical record in order to meet the definition of each procedure code. Procedure code G0179 is the Physician recertification services for Medicare covered services provided by a participating home health agency (patient not present), including review of subsequent reports of patient status, review of patient's responses to the oasis assessment instrument, contact with the home health agency to ascertain the follow-up implementation plan of care, and documentation in the patient's office record, per certification period. Procedure code G0180 is the Physician certification services for Medicare-covered services provided by a participating home health agency (patient not present), including review of initial or subsequent reports of patient status, review of patient's responses to the oasis assessment instrument, contact with the home health agency to ascertain the initial implementation plan of care, and documentation in the patient's office record, per certification period.

9.   Is a notation from the physician to the OASIS document and the 485 form or that (s)he agrees with the OASIS document and the 485 form sufficient documentation for Re-Certification and Certification procedure codes (G0179 and G0180)?

No, a separate note should be documented by the physician in the patient’s medical record. Review of any initial and subsequent reports of the patient’s status, review of the OASIS and the status of how the patient is responding to the OASIS instrument, and any contact with the home health agency to ascertain the initial or follow up implementation plan of care should also be documented in the patient’s medical record. Documentation supplied by the home health agency or hospice cannot be used in lieu of the physician documentation.

10.   How much coordination does Medicare require between the physician and the home health agency in order to bill the Re-certification and Certification procedure codes, G0179 and G0180?

Coordination must occur between the physician and the home health agency to ascertain the follow-up implementation plan of care, and any documentation in the patient's office record in order to bill the Recertification and Certification procedure codes, G0179 and G0180, per certification period.

11.   How can you review the responses to the OASIS document when you are signing/certifying the document initially?

Procedure code G0180 is the Physician certification services for Medicare-covered services provided by a participating home health agency (patient not present), including review of initial or subsequent reports of patient status, review of patient's responses to the oasis assessment instrument, contact with the home health agency to ascertain the initial implementation plan of care, and documentation in the patient's office record, per certification period. The physician should review the OASIS assessment instrument and document the status of the patient as it relates to the OASIS assessment. The physician documentation should also summarize the plan of care, which should include, but not be limited to: the type of services to be provided to the patient, both with respect to the professional who will provide them and the nature of the individual services, as well as the frequency of the services.

12.   Do procedure codes G0179 and G0180 require the physician to spend 30 minutes of time with the patient per calendar month?

No, procedure codes G0179 and G0180 are not time based codes and should be billed based on certification period. Care Plan Oversight procedure codes G0181 and G0182 are time based codes and must have documentation of a minimum of 30 minutes of countable services towards CPO documented during the calendar month for which payment is sought.

13.   Does the physician have to sign the OASIS form in addition to the 485 form?

The physician does not have to sign the OASIS form; however, the physician should document any review of initial and subsequent reports of the patient’s status, review of the OASIS and the status of how the patient is responding to the OASIS instrument, and any contact with the home health agency to ascertain the initial or follow up implementation plan of care. Documentation supplied by the home health agency or hospice cannot be used in lieu of the physician documentation.

14.   What is the difference between procedure codes G0179, G0180, G0181, and G0182?

G0179 is the Physician recertification services for Medicare covered services provided by a participating home health agency (patient not present), including review of subsequent reports of patient status, review of patient's responses to the oasis assessment instrument, contact with the home health agency to ascertain the follow-up implementation plan of care, and documentation in the patient's office record, per certification period.

G0180 is the Physician certification services for Medicare-covered services provided by a participating home health agency (patient not present), including review of initial or subsequent reports of patient status, review of patient's responses to the oasis assessment instrument, contact with the home health agency to ascertain the initial implementation plan of care, and documentation in the patient's office record, per certification period.

G0181 is the Physician supervision of a patient receiving Medicare covered services provided by a participating home health agency (patient not present) requiring complex and multidisciplinary care modalities involving regular physician development and/or revision of care plans, review of subsequent reports of patient status, review of laboratory and other studies, communication (including telephone calls) with other health care professionals involved in the patient's care, integration of new information into the medical treatment plan and/or adjustment of medical therapy, within a calendar month, 30 minutes or more.

G0182 is the Physician supervision of a patient under a Medicare approved hospice (patient not present) requiring complex and multidisciplinary care modalities involving regular physician development and/or revision of care plans, review of subsequent reports of patient status, review of laboratory and other studies, communication (including telephone calls) with other health care professionals involved in the patient's care, integration of new information into the medical treatment plan and/or adjustment of medical therapy, within a calendar month, 30 minutes or more.

15.   How do you bill CPO services for a patient who is deceased?

Bill the service with the date of the month that the service occurred and during the month that the patient was alive.

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