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Care Plan Oversight Billing Guidelines

Care Plan Oversight (CPO) reimbursement is an added incentive for physicians created by the Center for Medicare and Medicaid Services (CMS). While many doctors are continuously involved in their patient’s care, many do not take advantage of the reimbursement.

In order to start benefiting from this great incentive, MedStar Visiting Nurse Association (VNA) is here to help you step-by-step.

Before Billing for CPO Be Sure:

  • Patient has received Medicare-covered home health services.
  • Physician has devoted 30 minutes or more to supervision of the patient’s care in a given month.
  • Physician has furnished a service requiring face-to-face contact with the patient at least once during the six month period before the month for which CPO payment is first billed.
  • Physician does not have a significant financial or contractual relationship with the home health agency.
  • Physician is the one and only attending physician to bill for CPO for the patient during a calendar month.
  • If physician is billing for CPO services during a postoperative period, physician must document in the patient’s medical record that the CPO services are unrelated to surgery.
  • Physician has the provider number of patient’s home healthcare agency.
  • Physician who bills CPO is the same physician who signed the home health plan of care and personally furnished the services.
  • Physician is not billing for Medicare End-Stage Renal Disease (ESRD) capitation payment and CPO for the same beneficiary during the same month.

To help physicians take full advantage of the Center for Medicare and Medicaid Services’ (CMS) Care Plan Oversight (CPO) incentive, MedStar Visiting Nurse Association (VNA) created a list of acceptable, billable CPO services.

Billable CPO Services:

  • Activities to coordinate services (if the coordination of activities required the skill of a physician).
  • Documenting the services provided, which includes writing a note in the patient chart describing services provided, decision-making performed, and amount of time spent performing the countable services.
  • Medical decision-making
  • Review of charts, reports, treatment plans, labs or other test results, except for the initial interpretation or review of lab of test results that were ordered during or associated with a face-to-face encounter.
  • Telephone calls with other healthcare professionals (not employed in the same practice) involved in the care of the patient.
  • Team conferences (must document time spent per individual patient).
  • Telephone or face-to-face discussions with a pharmacist about pharmaceutical therapies

To help physicians take advantage of the Center for Medicare and Medicaid Services’ (CMS) Care Plan Oversight (CPO) incentive, MedStar Visiting Nurse Association (VNA) has created a list of non-billable CPO services.

Note: The services listed below are covered by Medicare, but they are either bundled into other services or included in the practice expense. Therefore, these services cannot be billed twice.

Non-Billable CPO Services:

  • Getting and/or filing the chart
  • Dialing the phone or time on hold
  • Informal consultations with health professionals not involved in the patient’s care.
  • Initial interpretation or review of lab or study results that were ordered during or associated with a face-to-face encounter.
  • Low-intensity services included as part of evaluation and management services.
  • Preparation or processing of claims
  • Staff time
  • Telephone call to patient or family, even to adjust medication or treatment.
  • Telephoning prescriptions in to pharmacists
  • Travel time