News: CMS clarifies E/M documentation, billing requirements for teaching physicians

On May 3, CMS released MLN Matters MM11171, which clarifies language in the Medicare Claims Processing Manual to match the current documentation policy for evaluation and management (E/M) services billed by teaching physicians. The article specifically clarifies two points regarding the extent to which the teaching physician participated in the services and the supporting documentation in the medical record, according to Revenue Cycle Advisor.

First, for E/M services billed by teaching physicians, the medical record must demonstrate that the teaching physician performed the service or, if the service was provided by a resident, the teaching physician was physically present during critical portions of the service. Secondly, the medical record must also demonstrate that the teaching physician participated in the management of the patient.

Specifically, the medical record must show the extent of the teaching physician’s participation in the review and direction of services. This may be demonstrated by notes created by physicians, residents, or nurses.

The clarification is retroactively effective to January 1. Medicare Administrative Contractors (MAC) will not search their files to reprocess claims, so providers must identify affected claims and bring them to the attention of their MACs for reprocessing, according to CMS.

Editor’s note: This article originally appeared in Revenue Cycle Advisor. To read the full edition of MLN Matters, click here. To read about coming E/M documentation requirement changes, click here. For more information advice regarding CDI’s involvement with E/M documentation, check out ACDIS’ book on the topic.