To the Editor:

Your series of articles on HCFA's new Medicare documentation rules are timely and appreciated.

What is missing in this rush to comply with HCFA's rules is any analysis of the cost-benefit ratio and other ramifications of these onerous regulations. Even with your coding tools, it appears that strict compliance with these rules would require five to 10 minutes for accurate coding and additional time for complete, supportive documentation. For anything above a 99212, coding and documentation could easily require as much time as that required for the actual service. To devote more time to paperwork, physicians must either see fewer patients per day, thereby decreasing access, or spend less time with patients, thus decreasing quality of care. Some physicians may simply choose to stop seeing Medicare patients. Unfortunately, insurance companies will likely try to adopt these same guidelines in the future.

I urge the AAFP and the AMA to consider all the problems created by HCFA's guidelines and to work with Congress to stop or change them before it is too late.