Physician Reimbursement

Care Plan Oversight Definition and Billing Instructions for Hospice Medicare Benefit Patients

Definition of Care Plan Oversight

Care Plan Oversight (CPO) exists where there is physician supervision of patients under care of hospices that require complex and multidisciplinary care modalities involving regular physician development and/or revision of care plans. Implicit in the concept of CPO is the expectation that the physician has coordinated an aspect of the patient's care with the hospice during the month for which CPO services were billed.

CPO: The Rules

  • Physician billing CPO must be the Hospice Attending Physician (and not employed by or a volunteer of the hospice).
    • Only one physician per patient can bill CPO.
    • NP can bill CPO if they are the Hospice Attending.
  • Physician must provide and document more than 30 minutes of CPO activity within the calendar month of claim.
  • Physician must have seen the patient face-to-face within 6 months of the first CPO service.
  • Billing code is G0182.

Activities that Count for CPO

  • Review of charts, reports, treatment plans, etc.
  • Discussion with other health care professionals involved in the patient's care.
  • Discussion with pharmacist about medications or adjustment of other medical therapies.
  • Medical decision-making.
  • Activities to coordinate care.
  • Documenting the services provided.

Activities that DO NOT Count for CPO

  • Time spent retrieving files or placing phone calls.
  • Telephone calls to patient or family.
  • Telephone calls to place a prescription.
  • Travel time.
  • Time spent preparing claims.
  • Initial interpretation of lab or study results ordered during a face-to-face encounter.

Billing for CPO

  • Place of service (POS) should be coded for "office" (11).
  • Dates of service must be the first and last date during which documented care planning services were provided.
    • Not just the first and last days of the month.
  • Patients are responsible for a 20% copay.


How to Bill Medicare for Patients Admitted to Hospice

Attending Physicians Billing Consulting Physicians Billing
Where to bill?

Bill Part B for Physician Services fee for services.

Use the GV modifier for hospice visits.

Use the GW modifier for services NOT related to the hospice diagnosis.

Consulting physician is any physician other than the attending physician who sees the hospice patient.

Bill Hospice for Consulting Physician Services related to the terminal illness diagnosis.

Who can bill?

Primary Physician
a) Office Visits
b) In-patient Visits
c) Home Visits
d) Nursing Home Visits

All other Physician(s) who see the hospice patient will bill the hospice. The hospice will then bill Medicare.
a) Office Visits
b) In-patient Visits
c) Home Visits

How Horizon Works with Home Health Agencies and Extended Care Facilities

Horizon is happy to work with your Home Health Agency. It is important to note that Home Health patients can also receive reimbursement for hospice or palliative care services. Home Health services are billed under Medicare Part A, and Palliative Care and Hospice services are billed under part B. The purposes of Home Health and Palliative Care and Hospice are a perfect complement to one another. Rest assured that your patient can benefit from both services simultaneously. We are honored to work in partnership with Home Health Agencies throughout our service area.

Horizon works with a multitude of senior residences and extended care facilities throughout the Chicago area. These include retirement communities and assisted living communities as well as skilled care facilities. In each facility, the Horizon staff works in partnership with nursing staff to ensure the very best in pain and symptom management.