HCFA Releases Draft E/M Documentation Guidelines
Published on Sun Oct 01, 2000
The Health Care Financing Administration (HCFA) unveiled proposed documentation guidelines (DGs) for physician evaluation and management (E/M) services this summer during a town hall meeting at its headquarters in Baltimore.
The June 2000 DGs are based on the 1995 version, a move heralded by family physicians and coders. HCFA had developed 1997 E/M guidelines intended to replace the 1995 version, but those were viewed as overly complex, requiring more documentation than clinically necessary. The June 2000 proposed DGs also replace a draft that was circulated in 1999.
We appreciate HCFAs return to the 1995 guidelines as a starting point for any new documentation guidelines, Lanny Copeland, MD, board chair for the American Academy of Family Physicians (AAFP), wrote in a letter to HCFA. In our experience, family physicians were more comfortable with the 1995 documentation guidelines, especially the examination portion, which emphasized a multisystem approach that is consistent with family practice. Although not perfect, the 1995 documentation guidelines did have much to commend them relative to the 1997 documentation guidelines and the proposed 1999 documentation guidelines. Indeed, we described the 1997 documentation guidelines as too flawed to be fixed.
According to HCFA, the June 2000 DGs are designed to reduce the volume of regulations and complex requirements that have baffled physicians and coders alike. They eliminate all references to shaded systems and bullets, and reduce element-counting hallmarks of the 1997 version. In addition, the new system will feature specialty-specific vignettes to help physicians and coders assign appropriate service codes.
After pilot testing, modifications and a physician education phase, the final version of the June 2000 DGs is expected to take effect in early 2002.
June 2000 Draft Represents a Mixed Bag
We believe our new, simpler guidelines will provide clear and unambiguous guidance and streamline the documentation required for clinically appropriate record keeping and verification that services were medically necessary and rendered as billed, says Nancy Ann DeParle, HCFA administrator. HCFA officials also stressed that clinical care, not documentation, should be a physicians primary focus, and that the new draft guidelines are designed to support this.
Kent Moore, manager of healthcare financing and delivery systems for the AAFP, notes that although many of the proposed DGs would simplify family practice coding, other modifications may be disadvantageous.
Evaluating the proposal in the context of the three primary areas of emphasis for family practice E/M visits physical examination, history and medical decision-making Moore points out some pluses and minuses. I would rate the changes in the examination portion as a plus and the changes in the history section a minus. The modifications to the medical decision-making (MDM) portion are still a big question mark.
Physical Examination Components
The key benefit to [...]
