Healthcare Reform

Guidelines to Submit a Claim for Care Plan Oversight

May 10, 2017

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.