It wouldn't be just 5's it would be 4's also in the case of new and consults. The exam requirements are the same.
They are hard to hit in ortho, at least in my experience. The 97 guidelines have single system exams one of which is MS. That is a bit misleading though because there is still a lot of work in a "single" system exam. The other option you have is time, which again in my experience with ortho is not going to help you hit a 4 or 5 either.
ROS for a comprehensive history is 10 or more and not hard to hit. Many practices use a form the patient fills out that has all 14 systems listed and then the provider goes over it and documents they did.
For an established patient it is only 2 of 3 so hitting a 5 is not always linked to the level of exam.
Don't forget the medical necessity part though. Any visit can be documented to show a comprehensive history, exam, and high MDM but that doesn't mean it is appropriate.
Bottom line, they need to do what is medically necessary, document what they do, and bill based on the documentation. If they never hit a 4 or 5 so be it, at least they are compliant.
Laura, CPC, CEMC