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Annual Wellness: Cognitive?


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Need the group's opinion on this: A doctor is doing Annual Wellness Visits, and he still does a physical exam. He wants to use the Psychiatric system exam as the "cognitive" assessment for the AWV.
On his paper form, he makes a check mark to indicate that the patient has a normal response to: "Alert & oriented to person/place/time." What does the group think insofar as that being enough for an assessment of the patient's cognitive skills?

Medicare's Preventive Service Guide states that for the AWV's a doctor must perform "Detection of any cognitive impairment that the beneficiary may have (includes the assessment of beneficiary's cognitive function by direct observation, with due consideration of information obtained by way of patient reports or concerns raised by family members, friends, caretakers or others;" So, Medicare is saying the provider must "detect" cognitive impairment by direct observation and by gathering additional information from reports and relatives, but they're not telling the provider to administer specific testing to a patient.

This same doctor is using 2 ADL assessment tools, and the Geriatric Depression Scale, plus the new Health Risk Assessment sample provided by the CDC (http://www.cdc.gov/policy/opth/hra/FrameworkForHRA.pdf).

But I am worried that his cognitive assessment would not be bullet-proof upon audit. Opinions?
Thanks, Deb