ED Coding and Reimbursement Alert

Documentation Faux Pas for New TP Guidelines

For the new teaching physician guidelines, some documentation decisions do not pass muster. Make sure you don't submit insufficient physician documentation, and apply documentation rules to the wrong codes.

Unacceptable Documentation

According to the guidelines, the following examples of teaching physician documentation are unacceptable and won't get your physicians paid:

  • "Agree with above" ... followed by legible countersignature or identity
  • "Rounded, reviewed, agree" ... followed by legible countersignature or identity
  • "Discussed with resident. Agree" ... followed by legible countersignature or identity
  • "Seen and agree" ... followed by legible countersignature or identity
  • "Patient seen and evaluated" ... followed by legible countersignature or identity
  • A legible countersignature or identity alone.

    Such documentation is unacceptable because it does not make it possible to determine whether the teaching physician was present, evaluated the patient, and/or had any involvement with the plan of care.

    Time-based codes

    With all the excitement brewing around the new teaching physician guidelines, emergency departments are confusing who and what falls under the guidelines.

    The new TP rules don't apply to time-based codes such as critical care, says Robert Polglase, MD, JD, CEO of Stratagem Group Inc. in Augusta, Ga.

    For time-based codes, the payment is made to teaching physicians for their involvement that does not include the resident time, reiterates Marianne Wink, RHIT, compliance analyst and educator at Strong Health Compliance Office in Rochester, N.Y.

    So for 99291 (Critical care, evaluation and management of the critical ill or critically injured patient; first 30-74 minutes) and +99292 (... each additional 30 minutes), and inpatient discharge codes for greater than 30 minutes, the teaching physicians must document the time effort that does not include resident time.

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