Coincidentally, I was just looking into CPO. See the Medicare Benefit Policy manual (100-2) Chapter 15, Section 30.G and the Medicare Claims Processing Manual (100-4) Chapter 12, Section 180 for CMS guidelines.
The Medicare Benefit Policy Manual states, "The physician who bills CPO must be the same physician who signed the home health or hospice plan of care" and from this I infer that any specialist would qualify.
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