Care Plan Oversight

Care Plan Oversight (CPO) is physician supervision of patients under either the home health benefit where the patient requires complex or multi-disciplinary care that will require ongoing physician involvement.  Basically, CPO reimbursement allows physicians to bill Medicare for their time overseeing the care provided to patients that receive home care.  Medicare does not pay for care plan oversight services for non-skilled nursing facilities or skilled nursing facility patients.  If you or your loved ones receive Medicare benefits, you must meet certain criteria for coverage of CPO for the home health services that will be provided for you by Total Home Health.  Listed below are the criteria you must meet to qualify for CPO coverage:

ü  As mentioned above, the client must require complex or multi-disciplinary care modalities requiring ongoing involvement of a physician for the entire plan of care.

ü  Care Plan Oversight (CPO) services are furnished during the period in which the client was receiving Medicare-covered home health agency services.

ü  The physician who submits the claim for CPO must be the same physician that signed the home health plan of care.

ü  The physician must be present for at least 30 minutes of CPO within the calendar month.  Time counted toward CPO may not include time that is spent by a nurse or time spent consulting with a nurse regarding client care.

ü  Time counted toward hospital discharge management or discharge from observation may not be counted toward CPO.  Services that are separately documented and that are provided after the patient is physically discharged may then be counted toward CPO.

ü  The physician provided a covered service that required a face-to-face encounter with the client within 6 months immediately preceding the CPO service.  EKG, laboratory, and surgical services do not meet this face-to-face encounter requirement.

ü  The CPO service may not be routine post-operative care provided during the global surgery period by the surgeon.

ü  For home health CPO, the physician may not have a “significant financial or contractual interest in the home health agency.”

ü  CPO services must always be submitted by the same physician that provided the services.

ü  Services provided “incident to” a physician’s service may not be counted toward the 30-minute requirement for CPO.

ü  The same physician may not submit a claim for both CPO and end stage renal disease (ESRD) capitation payment for the same client during the same month.

ü  The physician must document, in the patient’s medical record, the services furnished to the patient, along with the date and length of time associated with these services.

Within the concept of Care Plan Oversight (CPO) is the expectation that the physician has coordinated an aspect of the patient’s care with the home health agency during the month for which CPO services were billed.  Nurse practitioners, physician assistants, and clinical nurse specialists, practicing within the scope of State law, may bill for CPO.  These non-physician professionals must have been providing ongoing care for the client through evaluation and management services.

The professional staff the make up the Total Home Health team abides by the criteria mentioned above to incorporate CPO into our home health programs for Medicare reimbursement.  Review your benefits today and feel free to discuss this with our team at your discretion so that we can answer any questions that may arise!