User Guide — Care Plan Oversight FAQ

Care Plan Oversight is supervision of patients under care of home health agencies or hospices that require 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 with other health professionals not employed in the same practice who are involved in the patient's care, integration of new information into the care plan, and/or adjustment of medical therapy.

"Providers billing for CPO must submit the claim with no other services billed on that claim and may bill only after the end of the month in which CPO services were rendered. CPO services may not be billed across calendar months and should be submitted (and paid) only for one unit of service."

- (CMS Publication 100-04, Chapter 12, Section 180.1, A)

CPO and home health certification and recertification is not a face-to-face visit with the patient. It is a period of at least 30 minutes in which the physician is writing or updating care plans, reviewing patient status, and communicating with other healthcare professionals and must be billed with the following codes: G0179, G0180, G0181, or G0182. Other types of home health or hospice with the patient should be billed using the appropriate HCPCS code for home health or hospice.

The services that count toward the 30‑minute period are:

• Review of charts, reports, treatment plans, or lab or study results, except for the initial interpretation or review of lab or study results that were ordered during or associated with 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 (time spent per individual patient must be documented)
• Telephone or face-to-face discussions with a pharmacist about pharmaceutical therapies
• Medical decision-making
• Activities to coordinate services are countable if the coordination activities require the skills of a physician

• G0181 — 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 healthcare 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 — 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 healthcare 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.

• G0179 — Physician recertification for Medicare-covered home health services under a home health plan of care (patient not present), including contacts with home health agency and review of reports of patient status required by physicians to affirm the initial implementation of the plan of care that meets patient's needs, per recertification period.
• G0180 — Physician certification for Medicare-covered home health services under a home health plan of care (patient not present), including contacts with home health agency and review of reports of patient status required by physicians to affirm the initial implementation of the plan of care that meets patient's needs, per certification period.

Medicare requires that place of service 11 (office) be used when billing these codes, as this is not a face-to-face visit with the patient, but work that is performed by the provider in an office setting.

Medicare requires the 6‑digit Medicare Hospice/HHA number. On the CMS‑1500, the 6‑digit Medicare Hospice/HHA number is reported in box 23. Physicians are responsible for obtaining the HHA or Hospice Medicare provider numbers. Additionally, physicians should provide their UPIN to the HHA or Hospice furnishing services to their patient.

On the Charge Entry or Claim Edit page, go to the Service Type Add-on section. Check the box for Hospice/HHA and then click choose/view next to the Hospice/Home Health Agency label, and search for the hospice or home health agency.

• If found, make sure all information is complete, including the Hospice/HHA number at the bottom of the entry box.
• If not found, click add new referring provider and complete each entry including name, address, and Hospice/HHA ID number.

Note: A claim rule assigns HOLD status to all claims billed with procedure codes 99374, 99375, 99377, 99378, G0179, G0180, G0181, and G0182 that do not contain the complete name and address of the Hospice/HHA facility and Medicare ID number.