The Documentation Guidelines: Read 'em and Weep
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Fam Pract Manag. 1998 Apr;5(4):6.
“The American Academy of Family Physicians strongly believes that the new E/M documentation guidelines as currently constructed are unacceptable and cannot be fixed by minor alterations. Accordingly, we urge the Health Care Financing Administration to recall the guidelines and suspend the July 1 implementation date for their usage.”
So said Neil Brooks, MD, the president of the AAFP, in testimony given before the Practicing Physicians Advisory Council just days before our press time. His testimony, which argued that following the guidelines is so time-consuming that it interferes with patient care, may well echo the frustration you have felt in trying to figure out how to live with the guidelines in your practice. He was certainly speaking for a good number of family physicians who have called the Academy recently to complain about the guidelines.
And it really has been in recent months that resistance to the guidelines has risen sharply — despite the fact that they've been around since 1994. The causes of the sudden escalation of opposition have been the recent addition of significantly more involved guidelines for exam documentation and HCFA's announcement that it will begin random, prepayment reviews of E/M claims. Thus, the guidelines have developed teeth at the same time that they've developed complications. This makes the impending date of implementation (which has already been postponed from Jan. 1 to July 1 of this year in response to early protests) a black day on many calendars. The guidelines that seemed merely burdensome to the physicians who bothered with them now seem frankly intolerable to many.
At this point, it's hard to see what the result of the clamorous protests will be. HCFA is legally required to do something to review utilization patterns of physicians and other providers of Medicare services, and the lack of a yardstick against which to measure E/M utilization was a significant problem —a problem the guidelines are intended to solve. Will complaining change the guidelines? Maybe. Will it cause another postponement of the implementation date? Maybe. But it seems foolhardy to count on either eventuality. You may very well find yourself celebrating Independence Day by trying to absorb 50-odd pages of guidelines in hopes of optimizing your chances of surviving a Medicare audit. You may weep, yes. But it's important to read them and understand them.
With that in mind, we at Family Practice Management will continue to do everything we can to educate readers about the guidelines — and especially to provide tips and shortcuts to make the intolerable manageable. The article in this issue by Carole Guillaume, MD, is a good example of that effort; we're also continuing to develop a new edition of the FPM monograph Mastering Medicare's Documentation Guidelines, which may be available by the time you read this. At the same time, we'll watch the developing situation carefully and keep you up-to-date in our Monitor and Medicare Update departments. The more you know about the guidelines and the controversy surrounding them, the better off you'll be. We'll help in every way we can.
Robert Edsall is editor-in-chief of Family Practice Management.
Copyright © 1998 by the American Academy of Family Physicians.
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