CMS clarifies documentation for teaching physicians' E/M services

Many family physicians are teachers, and they often provide evaluation and management (E/M) services when teaching. Appropriately documenting those services is important to help substantiate payment, so teaching physicians should know that the Centers for Medicare & Medicaid Services (CMS) has revised its claims processing manual to clarify its documentation policy for teaching physicians and E/M services.

The CMS has issued two areas of clarification:

• For the purposes of payment, a teaching physician who bills an E/M service must demonstrate in the medical record that: a) he or she performed the service or was physically present during the key or critical portions of the service when performed by the resident; and b) he or she participated in the management of the patient.

• Each Medicare patient’s medical record must document the extent of the teaching physician’s participation in the review and direction of the services furnished to that patient. That participation may be demonstrated by the notes in the medical record made by physicians, residents, or nurses.

Medicare administrative contractors (MACs) will not search their files to reprocess claims that may be affected by this clarification. However, if you point out an affected claim, the MAC will adjust it. The changes are effective for dates of service on or after Jan. 1 but will not be implemented until July 29.

– Kent Moore, Senior Strategist for Physician Payment at the American Academy of Family Physicians

Posted on May 10, 2019 by Kent Moore