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Requirements still the same
In the November issue of Hospice Management Advisor, Medicare coding experts advised how hospices should train referring physicians on how to use care plan oversight (CPO) codes listed in the CPT 2000. In December, however, the Health Care Financing Administration released new guidelines for CPO billing.
The changes set for 2001 have to do with little-used care plan oversight codes, currently 99374 and 99375 for home health and 99377 and 99378 for hospice.
HCFA has released two new codes to replace those found in CPT 2000. Physicians will have to bill CPO in 2001 using the HCPCS code, G0181 and G0182, new temporary codes for procedures and professional services. G0181 will apply to home health patients and G0182 will apply to hospice patients.
While the codes have changed, the requirements related to using them have not, says Nancy Cothern, business manager at Baptist Cancer Institute in Jacksonville, FL.
For example, Palmetto Government Benefits Administrator, a Medicare payer, offers the following directives to its Medicare providers:
• 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, 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 care plan oversight (see details of services that may be included below) within the calendar month for which payment is claimed and no other physician has been paid for care plan oversight within that calendar month.
• The physician must have provided a covered physician service that required a face-to-face encounter with the beneficiary within the six months immediately preceding the provision of the first care plan oversight service (a face-to-face encounter does not include EKG, lab services, or surgery).
• The care plan oversight 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 Care Plan Oversight must document in the patient’s record which services were furnished and the date and length of time associated with those services.
In addition to the numerous rules associated with CPO codes, tracking the length of each phone call used to oversee patient care can prove to be a tedious task. Nevertheless, physicians must document the length of time to choose the appropriate time-based code.
"If you don’t track your calls, you won’t get paid," says Cothern.
She recommends oncology practices implement a log system to routinely track the length of time a physician spends on the phone reviewing home health or hospice patient care.
In addition to new CPO codes, oncology physicians who refer their patients to home care will have an additional opportunity to bill Medicare for home care-related work. HCFA also established a new code set for certifying and recertifying home health plans of care.
The new payment was added to encourage greater physician involvement, HCFA officials say. Code G0179 will be used to recertify a patient who has received home health services for at least 60 days, or one certification period. Code G0180 applies to patients who have not received Medicare-covered home health services for at least 60 days. Oncologists will earn about $61 for each certification and $53 for each recertification. The two amounts are based on national averages, amounts adjusted by region, and other factors that will not be available until the final physician fee schedule is released.