Wiki Guidelines for Residents and Teaching Physicians

[Priscilla Keogh]

I have been coding for about 6 years, but have never worked at a teaching hospital. As far as I can tell after looking at the CMS website, in order for a teaching physician to bill an E/M visit, he must see the patient and put an attestation on the documentation that he examined the patient and agrees with what the resident has documented. I am being told by my compliance officer and higher ups not to hold the charge until physician attestation has been added, just let the physician knows he needs to do it and go ahead and bill the charge. This goes against everything I have been taught. What should I do?

 

[dcraven]

Teaching Physician Guidelines

If the service involves a resident - without an attestation there is not a billable service. The guidelines state:
"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 portions 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, reviewers will combine the
documentation of both the resident and the teaching physician."

At the time of coding - If you do not have appropriate documentation reflecting the extent of participation of the teaching phy. You may be coding a service that is not appropriate.

dcraven

 

[FTessaBartels]

I can't believe your compliance office said that!

Our compliance office would NEVER tell us to bill out a service without the attestation statement on it. If, upon audit, they don't feel the attestation is sufficient to meet CMS guidelines they make us send a corrected claim and refund any payment.

BUT ... Many commercial payers do not follow the same strict guidelines as Medicare / Medicaid. In fact, for most commercial payers, "supervision" is all that is required, and that can be via any means of modern communication (i.e. the resident called the attending faculty physician and receives verbal concurrence on the plan of treatment).

I would send an email to compliance asking for clarification of the protocol when there is a missing attestation statement. Get a response in writing, and KEEP IT for your records.

F Tessa Bartels, CPC, CEMC