Healthcare Reform
May 10, 2017

Guidelines to Submit a Claim for Care Plan Oversight

Healthcare professional shows patient info on clipboard

Physicians spend valuable time coordinating care for terminally ill patients and their caregivers. Care plan oversight (CPO) is a service for which certain clinicians¹ can bill Medicare in the absence of a face-to-face patient encounter. Many providers coordinate care as required, but do not submit a claim. They are losing deserved revenue².

CPO requirements³

  • The beneficiary requires complex or multidisciplinary care modalities that call for ongoing clinician involvement in the plan of care
  • CPO is furnished during the period in which the beneficiary received Medicare-covered hospice services
  • The clinician who billed for CPO is the clinician who signed the hospice plan of care
  • The clinician provided at least 30 minutes of CPO within the calendar month for which payment is claimed
  • The clinician provided a covered physician service that required a face-to-face encounter with the patient within six months of billing for the CPO
  • Only one clinician per month billed for CPO
  • The clinician did not bill Medicare for an end-stage renal disease (ESRD) capitation payment for the same beneficiary during the same month

CPO services³

  • Regular physician development and/or revision of care plans
  • Review of subsequent patient status reports
  • Review of related laboratory and other studies
  • Communication with health professionals not employed in the same practice who are involved in the patient’s care
  • Integration of new information into the medical treatment plan
  • Adjustment of medical therapy

Use Healthcare Common Procedure Coding System (HCPCS) code G0182 when CPO is provided to patients who have elected hospice from a Medicare-approved hospice provider.


1Physicians, nurse practitioners, clinical nurse specialists and physician assistants.

2Palmeter, MC. “Take a Closer Look at Care Plan Oversight.” American Academy of Professional Coders. blog/27473-take-a-closer-look-at-care-plan-oversight/

3Medicare Benefit Policy Manual Chapter 15 – Covered Medical and Other Health Services. (Rev. 228, 10-13-16) https://www.cms. gov/Regulations-and-Guidance/Guidance/Manuals/downloads/ bp102c15.pdf

CPT is a registered trademark of the American Medical Association.