ED Coding and Reimbursement Alert

Last November, the Department of Health and Human Services released a Medicare transmittal relaxing documentation requirements for E/M services rendered by residents and billed by teaching physicians.

The guidelines are a "big deal" for emergency departments, says Mike Lemanski, MD, at Baystate Medical Center, a large teaching hospital with an E/M residency program of 36 residents.

"There is no question that these clarifications to the teaching physician rules are extremely important to any ED," echoes Robert Polglase, MD, JD, CEO of Stratagem Group Inc. in Augusta, Ga. Many emergency departments have not realized the impact these rules could have on E/M coding, so we're here to spread the news. In minimizing documentation requirements for TPs, the guidelines will definitely impact coding in the ED, decreasing redundant documentation time and increasing physician productivity which means you'll see more resident handwriting and, perhaps, more physician bills.

Read on to get an in-depth look at these regulations, and inform your office: Though physicians should benefit from these guidelines, you need to be aware of some ambiguous documentation practices that could get your practice in hot water. Relaxed Physician Documentation Requirements Medicare Transmittal 1780 is influential because it minimizes the teaching physician documentation requirements for E/M services rendered by the resident. So, coders, expect less documentation for E/M services. The new requirements allow physicians simply to "state" that they saw and evaluated the patient and that they agree or disagree with the resident's findings, Lemanski says. In other words, "TPs do not need to repeat documentation already provided by the resident." In the past, TPs had to document the key elements of the E/M evaluation: the Hx, PE, and MDM, Lemanski says.

You should make sure your physicians meet the requirements stated directly in the transmittal excerpt below: 1. Evaluation and Management (E/M) Services: For a given encounter, the selections of the appropriate level of E/M service should be determined according to the code definitions in the American Medical Association's Current Procedural Terminology (CPT) and any applicable documentation guidelines. For purposes of payment, E/M services billed by teaching physicians require that they personally document at least the following:

a. That they performed the service or were physically present during the key or critical parts of the service when performed by the resident; and

b. The participation of the teaching physician in the management of the patient. When assigning codes to services billed by teaching physicians, reviews will combine the documentation of both the resident and the teaching physician. Documentation by the resident of the presence and participation of the teaching physician is not sufficient to establish the presence and participation of the teaching physician. On medical review, the combined entities into the medical record [...]