What are the rules governing NPs/PAs billing for CPO? Does the physician need to see the patient?
NPs and PAs can bill for Care Plan Oversight. The Medicare Benefit Policy Manual, Chapter 15, clarifies that nurse practitioners, physician assistants, and clinical nurse specialists, practicing within the scope of State law, may bill for CPO and outlines the requirements for billing. They are reimbursed at 85% of the physician rate. There is no requirement for the physician needing to see the patient in order to sign a 485. Billing for certification requires that you attest that the patient is under your care. For CPO, a face-to-face visit must have occurred within six months prior to CPO date of service. • Can a NP or PA sign the plan of care for CPO? No. Medicare regulations require a physician to sign the home health plan of care. However, if the NP/PA performs 30 minutes or more of CPO, and has his/her own billing number, he/she can bill independently for those services. • Can the 30 minutes of CPO be split between physician and NP/PA? No. Only the practitioner that performs can b
