In Transmittal, CMS Cites Teaching Physician Documentation Change

Teaching physicians are now free to let residents and nurses document most of their evaluation and management (E/M) services, as long as their physical presence is noted in the medical records, according to a new Medicare transmittal (4283). The April 26 transmittal described in a couple sentences a break with the past, which was first announced in the 2019 Medicare Physician Fee Schedule final rule.

“The patient medical record must document the extent of the teaching physician’s participation in the review and direction of the services furnished to each beneficiary,” the transmittal states. “The extent of the teaching physician’s participation may be demonstrated by the notes in the medical records made by physicians, residents, or nurses.”

The language in the transmittal matches the language in the regulation, although teaching hospitals may not take advantage of it. Instead, they may benefit during audits when teaching physicians have only co-signed the resident’s notes, says Betsy Nicoletti, a consultant in Northampton, Massachusetts.

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