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Atlanta program offers Shot in the Arm
One of the hallmarks of hospice care is that the physician-patient relationship is not severed even when curative efforts have run their course. A physician who has referred a patient to a hospice program is still considered the patient’s primary physician.
So, it stands to reason that the physician should be paid for his or her services. But many physicians are unaware of Medicare rules regarding reimbursement following an admission to hospice or home health.
Hospices can bolster their relationships with referring physicians by offering educational assistance to teach physicians how to get paid for the valuable work they do for patients at the end of life.
Visiting Nurse Health System in Atlanta, which runs a home health agency and hospice, provides one example of this kind of service. Its "Shot in the Arm" program provides information on coding and eligibility requirements to help physicians navigate the tricky world of reimbursement and compliance.
The 15-page information packet helps physicians make appropriate referrals without fear of running afoul of Medicare requirements, says Barbara Austin, RN, MN, director of clinical development for Visiting Nurse Health System.
In the packet, the agency says that when a patient is referred to hospice, that doesn’t mean the physician no longer has a say in treatment, nor does it mean there are no longer any billing opportunities for the physician. There are several case management-related services that can be provided by a physician whose patient is being cared for in a home health or hospice setting, including codes G0181 and G0182 for care plan oversight (CPO).
Physicians often take an active role in monitoring their patients’ progress following a referral to home health or hospice. They may take part in interdisciplinary team meetings, hold telephone conversations with other health care professionals, and recertify patients for continued care under home health.
All these services may represent a significant portion of a physician’s time and may be deserving of payment. The problem is that there are a number of case management codes to choose from, most of which are not covered under Medicare or are no longer being used.
Choose CPO over 99361, 99371-99373
At first blush, code 99361 (medical conference) seems an accurate and appropriate code to report a meeting with home health workers or hospice interdisciplinary team members. In CPT 2001, this code is described as a "medical conference by a physician with interdisciplinary team of health professionals or representatives of community agencies to coordinate activities of patient care."
Code 99361 is not a separately payable item and is always considered part of evaluation and management services, the document advises.
In the same vein, codes 99371-99373 (telephone call) seem appropriate for telephone conferences for the purpose of coordinating care. According to the CPT, 99371-99373 describes a telephone call by a physician to a patient or health care professional for medical management or coordinating medical management. But Medicare policy excludes payment of these codes.
While it seems that the codes that best describe the case management efforts of physicians lead to no reimbursement, care plan oversight codes encompass the services described in 99361 and 99371-99373. More importantly, they are reimbursable, says Austin.
Be aware of two new codes
It is important to note that the Center for Medicare Services (formerly the Health Care Financing Administration) released two new codes this year that are relevant to this area. Rather than using 99374-99375 (physician supervision) for home health and 99377 (physician supervision) for hospice, the correct care plan oversight codes are listed in HCPCS as follows:
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 revisions of care plans, review of subsequent reports of patient status, review of laboratory and other studies, communications [including telephone calls] with other health care 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 revisions of care plans, review of subsequent reports of patient status, review of laboratory and other studies, communications [including telephone calls] with other health care 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.
While the codes are new, the way to determine time spent performing care plan oversight remains the same. Practices must painstakingly document each minute the physician spends performing CPO services in a 30-day period. For every 30 minutes spent doing CPO each month, oncology practices should report either G0181 or G0182.
The definitions for both home health and hospice CPO point to seven services that can be used to tally CPO:
• review of charts, reports, treatment plans, and other test results;
• telephone calls (excluding time spent on hold) to hospice or home health representatives;
• team conferences;
• discussions with pharmacists about pharmaceutical therapies;
• medical decision-making;
• coordination of services;
• documenting the services provided in the patient chart.
Care plan oversight provided by a nurse, nurse practitioner, physician’s assistant, clinical nurse specialist, or other staff is not reimbursable, says Austin. CPO codes are reserved for services provided directly by a physician. Telephone calls to the patient or family made by someone other than the physician are not eligible for reimbursement.
Physician time spent calling in prescriptions to a pharmacy, retrieving a chart, or traveling are not considered eligible and cannot be used to sum up time spent performing CPO.
New recertification codes
In addition to new CPO codes, oncology physicians who refer their patients to home care should bill Medicare for certifying and recertifying services provided by a home health agency. The new codes were added to encourage greater physician involvement in their patients’ care.
Code G0179 (MD recertification, HAA patient) will be used to recertify a patient who has received home health services for at least 60 days, or one certification period. Code G0180 (physician certification services for Medicare-covered services provided by a participating home health agency [patient not present], including review of initial or subsequent reports of patient status, review of patient responses to OASIS assessment instrument, contact with the home health agency to ascertain the initial implementation plan of care and documentation in the patient’s office record, per certification period) applies to patients who have not received Medicare-covered home health services for at least 60 days. The national reimbursement average for G0180 is $73, and the national reimbursement average for G0180 is $53.These amounts will vary by region.