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acceptable prerequisite face-to-face encounters for CPO. EKG, lab, and surgical
services are not sufficient face-to-face services for CPO;
7. The care plan oversight billed by the physician was not routine post-operative
care provided in the global surgical period of a surgical procedure billed by the
physician;
8. If the beneficiary is receiving home health agency services, the physician did not
have a significant financial or contractual interest in the home health agency. A
physician who is an employee of a hospice, including a volunteer medical
director, should not bill CPO services. Payment for the services of a physician
employed by the hospice is included in the payment to the hospice;
9. The physician who bills the care plan oversight services is the physician who
furnished them;
10. Services provided incident to a physician’s service do not qualify as CPO and do
not count toward the 30-minute requirement;
11. The physician is not billing for the Medicare end stage renal disease (ESRD)
capitation payment for the same beneficiary during the same month; and
12. The physician billing for CPO must document in the patient’s record the services
furnished and the date and length of time associated with those services.
G. Medical Record Documentation for Part B Services
This medical record documentation requirement applies to Part B professional services
that are paid under the Medicare physician fee schedule. Accordingly, for Part B covered
services, the certified nurse-midwife, nurse practitioner, physician assistant, clinical nurse
specialist, and any individual who is authorized under Medicare law to furnish and bill
for their professional services, whether or not they are acting in a teaching role, may
review and verify (sign and date), rather than re-document notes in a patient’s medical
record made by physicians, residents, nurses, and students (including students in therapy
or other clinical disciplines), or other members of the medical team, including as
applicable, notes documenting the physician or nonphysician practitioner’s presence and
participation in the service.
For documentation requirements specific to E/M services furnished by physicians and
certain nonphysician practitioners, see Chapter 12, section 30.6 of the Medicare Claims
Processing Manual, publication 100-04.
30.1 - Provider-Based Physician Services
(Rev. 1, 10-01-03)
A3-3145, B3-2020.6, B3-8000-8099 (only instructions still applicable are included)