Chapter 7: CPO

(continued)
❏ The Certification process.
❏ Patient recertification process & requirements.
❏ Various other entities in patient care
supervised by the Physician/NPPs whose care
documentations can be valid for CPO.
❏ CPO minutes allocation to the patient for
services eligible within the certification period
in the calendar month.
❏ Verification & elimination of non-eligible
minutes for CPO.
Exam for the chapter
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The Patient Certification Process for HHA-H
❏ The certification of a patient for the Home Health Agency and Hospice is a
process which involves the F2F of the patient by a qualified Physician/NPP,
who details all the ailments including diseases & conditions on a SOAP
format note along with the Past Medical History (PMHx) and all other
ongoing treatments of the patient.
❏ This process also involves various personnel of Doctor Alliance who select
a suitable HHA-H based upon suitability factors such as insurance
acceptance, availability of staff at HHA-H who can provide services to the
patient, and the inclusion of patient’s address (ZIP) in their serviceable
location.

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❏ It also includes the agreed timeline for patient to be enrolled & provided
service. It is upon receipt of referral with clinical documentation from the Doctor
Alliance (who works on behalf of Physician Group), the HHA or Hospice starts
the certification process (as per the DA training of CMS-485 form for HHA-H).

❏ The duration of initial certification is 60 days for a patient for Home Health
Agency, and it is for 6 months (180 days) for a Hospice patient.

❏ Note: A patient with Dementia or other such conditions may be certified for a
suitable duration as per the clinical needs of the patient and we have seen the
certification to be for even 360 days but it is very rare. Additional justification
must be added in case a certification is other than 60 days for HHA or any other
longer duration over 180 days (6 months) for the Hospice patients.

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Additional Details of certification process
❏ Refer to the detailed Doctor Alliance Training Module 1, Chapter 4, Part A,
B and C of CMS-485 form to understand the various roles and
responsibilities of Doctor Alliance clinicians in certification process.
❏ The certification process uses the CMS-485 documentation which is
initiated by the Home Health Agency or the Hospice which receives a
referral from Doctor Alliance clinciain on behalf of the supervising MD or
other Physicians and/or Nurses, as per the applicable state laws.
❏ The follow-up of patient’s health status along with various
documentations by Doctor Alliance will be discussed in chapter 8 of this
training manual.

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Recertification of patient for HHA services
❏ As Per the regulations at 424.22(b)(1), recertification for the patient is required
at least every 60 days.
❏ Recertification for HHA services can only be done when there is a need for
continuous home health care after an initial 60-day episode.

❏ Also, if the below occurs, recertification can not be done:

❏ A. Patient-elected transfer; or
❏ B. Discharge with goals met and/or no expectation of a return to home health care.

These situations (above A and B), trigger a new certification, rather than a
recertification.

Note: Medicare does not limit the number of continuous episode recertifications for
patients who continue to be eligible for the home health benefit.
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Certifying Patients for the Medicare Home Health Benefit

Additional information for training can be found in the following presentation

PDF file (very important). The document is by CMS.

Link on Doctor Alliance server (Click here)

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CPO minutes allocation to the patient for services eligible within the certification
period in the calendar month
❏ CPO minutes are added with each processed documentation for patient care on
Doctor Alliance portal.
❏ The assigned clinician of Doctor Alliance needs to verify that the document
process as a result of patient care is valid and eligible to get CPO minutes.
❏ Maximum CPO minutes assigned on Doctor Alliance portal is usually limited to 5
CPO minutes per document but the Physician Group’s MD, other physician or
nurses may request to add additional minutes of CPO for a specific case, which
may be considered if the documentation requirements & justification for any
such additional CPO minutes are met.
❏ Except in rare cases (as above where Physician or Nurse request for addition
minutes with justification), Doctor Alliance clinician limits the maximum
assigned CPO minutes for each valid document to 5 CPO minutes.

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 ❏ A minimum of six valid patient care documentation is required to get a minimum of 30 CPO minutes for a calendar
month.
❏ Per eligible Patient care document = 5 CPO minutes
❏ Minimum number of document = 6 per calendar month (within certification period)

i.e. 5 CPO Minute per patient care document X 6 documents minimum

Total Minimum (eligible) = 30 CPO minutes per calendar month

Note:

❏ There is no MAXIMUM LIMIT for CPO that can be captured per calendar month for a particular patient. This is because
CPO minutes are added based upon eligible patient care done and there is no limit of care which may be needed for a
patient for a calendar month such as cases where a Pt has a form of Dementia such as Alzheimer’s Disease or any
other such disease & conditions which may be either chronic or acute & requires many patient care interventions per
calendar month. This makes addition of additional CPO minutes beyond 30 minutes justifiable. Patient care is a
complex process & requires a lot of documentation of care due to US state & federal guidelines including the need of
extensive documentation by the various insurance providers.
❏ In any case, the maximum billable minutes by the insurance providers for CPO per month can not exceed 30 CPO
minutes (this does not limit the services & patient care which can be provided to a Pt which may be as needed for the
particular case of the this patient.

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❏ A minimum of six valid patient care documentation is required to

get a minimum of 30 CPO minutes for a calendar month.

❏ Per eligible Patient care document = 5 CPO minutes

❏ Minimum number of document = 6 per calendar month (within certification

period)

i.e. 5 CPO Minute per patient care document X 6 documents minimum

Total Minimum (eligible) = 30 CPO minutes per calendar month

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Few points about Total Minimum (eligible) = 30 CPO minutes per calendar month
Note:
❏ There is no MAXIMUM LIMIT for CPO that can be captured per calendar month for a
particular patient.
❏ This is because CPO minutes are added based upon eligible patient care done and there
is no limit of care which may be needed for a patient for a calendar month.
❏ Example can be cases such as where a Pt has a form of Dementia such as Alzheimer’s
Disease or any other such disease & conditions which may be either chronic or acute &
requires many patient care interventions per calendar month.
❏ The above makes addition of additional CPO minutes beyond 30 minutes justifiable.
❏ Patient care is a complex process & requires a lot of documentation of care due to US
state & federal guidelines including the need of extensive documentation by the various
insurance providers.
❏ In any case, the maximum billable minutes by the insurance providers for CPO per
month can not exceed 30 CPO minutes (this does not limit the services & patient care
which can be provided to a Pt which may be as needed for the particular case of the this
patient.
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Concept of Calendar month for CPO
❏ CPO is billed per calendar month which is a total of 12 calendar months,
as per the law, i.e. January to December for Doctor Alliance.
❏ The clinicians associated with Doctor Alliance and assigned to various
Physician Groups (MD or any other Physician or Nurses), must work on a
daily basis for patient care goals of each assigned patient.
❏ The overall patient care goal for assigned clinicians is to improve the
Health-Related Quality of Life (HRQoL) of every patient on Doctor Alliance.
❏ Patient care documentation includes the

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Various other entities in patient care supervised by the Physician/NPPs
whose care documentations can be valid for CPO
❏ There are many entities including insurance provider, ancillary companies
and other outpatient providers & companies who help for various needs
of patient care.
❏ The ancillaries for patient care are listed as follows in the following
document by Doctor Alliance (this is only a list of providers & OTHER
ENTITIES; it is not in a particular sequence but all of these & many more
are part of patient care entity list).
❏ Patient Care Sphere Entities for DOctor Alliance (click here) to view the
PDF file on DA server & learn.

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Verification & elimination of non-eligible minutes for CPO.
❏ All the captured CPO minutes may NOT be eligible as per the applicable
rules & regulations of CPO. The Doctor Alliance clinician MUST verify if
each captured minute for the Pt is valid.
❏ For example:
❏ If a certification started on 14th of January 2022, then all the CPO minutes captured
before the start of certification date (i.e. 1 to 13 of January 2022) will not be valid to be
considered towards 30 eligible CPO minutes for the calendar month.
❏ Similarly, if a certification ended on January 17, 2022, then all CPO minutes captured after
such date will NOT be counted towards the total CPO valid for the calendar month (i.e. all
CPOs captured from Jan 18 to 31 of 2022, will not be counted towards January CPO
minutes).

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❏ Other examples
❏ Similarly, CPO for a continued Certification period can not be billed in the
same calendar month again as the initial certification end month. A patient’s
cert ended on April 22, 2022 and a valid recert is from April 23, 2022 which
gives two eligible windows in the calendar month for CPO i.e.
❏ 1st valid CPO window = April 1, 2022 to April 22, 2022
❏ 2nd Valid CPO window = April 23, 2022 to April 30, 2022
❏ However, only one of the above, either 1st or 2nd window period should
be considered for the billing of the CPO in the calendar month April 2022.
❏ The only 1 billing per calendar month rule ensures that multiple CPO
minutes are not billed per month. However, this should not impact the
care provided to the patient.

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❏ Other examples
❏ The patient care must be as per the eligible diseases & conditions
and the required patient care for the same. The physicians, and
nurses also get additional revenue from patient care. The CPO
minutes at HHA-H & revenue from it, is just an additional
reimbursement provided for overseeing the patient’s care at HHA
or Hospice.
❏ Patient care MUST NOT be based upon billing cycle but based
upon the actual care needed and billing CPO minutes should be
an outcome of the provided patient care.

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❏ Other examples
❏ A patient who is discharged on May 12 2022 but has a cert
continued till May 27 2022 can NOT have additional CPO
minutes from May 13 2022 to May 27 2022. The cert may
be continued as per the initial certification till the above
date i.e. May 27, 2022 in this case but the discharged
patient from the care of HHA or Hospice, due to ANY VALID
REASON, can NOT be considered for additional CPO
minutes after such a discharge date from the facility’s care.

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❏ Other examples
❏ Similarly, a patient who needs a Hospital Care in between
the CPO certification date, even after certification
approval, can not be considered for CPO from the date of
hospital visit & admission.
❏ Even if such patient is discharged after a few days, MUST
be considered for a NEW certification and not continued
with older certification as the patient is considered
discharged from HHA-H when the patient required a
hospital visit for any inpatient or emergency department.
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❏ Other examples
❏ A patient without a chronic disease or conditions which
need long-term care by a skilled service provider can not
be considered for CPO minutes or even certification at
HHA-H.

❏ Doctor Alliance clinicians should be careful when

evaluating the documents for patients on Doctor Alliance.

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❏ Other examples
❏ A patient whose cert period has only 1 or 2 days remaining
in a calendar month should be generally avoided for CPO
with that cert period of 1 or 2 days only, in a calendar
month.
❏ Example of such patient can be a Pt whose recert is ending
on May 2, 2022, (has only 2 days in May 2022), should
normally NOT be considered for CPO minutes unless
requested by MD or other Physician or nurse practitioner
to capture CPO with eligible supporting reason &
documentations provided for such a patient to Doctor
Alliance by the Physician Group.

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❏ Other examples
❏ Similarly, a patient without a valid certification but even
with eligible CPO minutes can not be considered for CPO
billing unless the certification document for such patient is
obtained on Doctor Alliance portal.
❏ Normally, the certification MUST be the first document for
a patient but due to unavoidable circumstances where
signature of other documents are required for a patient on
Doctor Alliance, other documents are sent before the
cert/recert document on the DA portal.
❏ A HHA or Hospice must be informed by the assigned DA
clinician of missing CMS-485 (cert/recert) on the DA portal.

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❏ Other examples
❏ CMS-485 form completed by the HHA or Hospice, based
upon the patient’s goals & orders as per the F2F
assessment by the physician group is a mandate for the
start of the care.

❏ Such completed CMS-485 should be added on DA portal or

can be created on DA portal with all the necessary details
as per the Part A, B, and C details (discussed in earlier
chapter 4 of Module 1, Doctor Alliance Training).

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❏ Other examples
❏ The DA clinician assigned on patient care for the Physician
must ensure that a valid CMS-485 is available prior to start
of CPO documentation.

❏ A DA clinician can also prepare/complete a CMS-485 form

on the DA portal for subscription HHA or Hospice, upon
completion of Doctor Alliance training on parts A, B & C of
the CMS-485 form.

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❏ Other examples

❏ The CMS-485 form prepared on Doctor Alliance for the

CPO eligible patient does NOT get any CPO minutes for
CERT/RECERT i.e. CMS-485 form itself.

❏ All the documents or minutes resulting from valid services

before start of certification or recertification are NOT
considered for patient’s CPO total for the calendar month.

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❏ Other examples

❏ The patient MUST have a valid Home Health Agency or

Hospice providing the care for any CPO minutes to be
eligible for a calendar month.
❏ CPO minutes are only valid if the services are done on or
after the start of certification or recertification date.
❏ The CPO minutes from valid services performed before or
after of certification period can NOT be included for CPO
even when the documentation was uploaded or created
within a valid certification period.

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❏ Other examples
❏ The patient care activities MUST be done within the
certification period and the resulting documentation MUST
also be done for the same within the same certification
period & the same calendar month.
❏ In rare cases, where late documentation is done due to a
valid reason by HHA-H, the document on the Doctor
Alliance portal must be prepared with the date being
corrected/updated so as to send the document prepared
to the right certification period & the correct calendar
month where it belongs. Such documentation will be
considered for their appropriate calendar month for the
30 minutes CPO total & for billing purposes.
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❏ Other examples

❏ A patient whose certification has any additional addendum received

later can be considered as additional change in plan of care and may

be provided with additional 5 CPO minutes.

❏ Such changes are rare on its own, and the assigned Doctor Alliance

clinician providing the patient care can initiate such changes &

documentation in consultation with the Physician Group’s MD, DO,

DPM or eligible Non-Physician Practitioners (discussed in detail in

Chapter 8).
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❏ The details of such innovative patient care methods is available in the

next chapter (8) for CPO along with additional methods for

improvement of patient care by the assigned Doctor Alliance clinician

for our subscription clients.

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