Retrospective risk adjustment teaching physician guidelines

jasmine.stone

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Who is the servicing provider for Retrospective: teaching physician or resident?

I am looking for a definitive answer on who is reported as the servicing provider for Retrospective Risk Adjustment chart reviews performed on members that were seen at a teaching hospital: the resident or the attending physician?

If you have any input on this, or can point me in the right direction, I would be so grateful! I, of course, have been scouring CMS's guides and other resources. Thank you!
 
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The teaching physician who is overseeing the resident must follow the guidelines as far as their participation in the service and the appropriate documentation needed. The joint effort by both the resident and the teaching provider, documented separately, are combined to assign the appropriate level for the service and the charges are billed under the teaching physician's name. Although the resident participated, the teaching provider bills and is therefore the serving/rendering provider. In other words, the resident can participate in treating the patient, however the teaching physician is ultimately responsible for that treatment and supervision of the patient, making him/her the rendering provider (servicing provider).
 
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Here's some additional information from an AAPC document:

"Teaching physician's must have a face-to-face encounter with the patient. In addition, they must document they were present during, or performed, the key or critical portions of the service when performed by the resident. The teaching physician's involvement in the management of the plan must also be documented.

The teaching physician must personally document:
- That he or she performed the service or was physically present during the key or critical portions of the service when performed by the resident; and
- The participation of the teaching physician in the management of the plan.

The documentation must include the services provided by the resident as well as the services provided by the teaching physician. If it is not clear that the physician performed a face-to-face encounter with the patient, the service cannot be billed. Documentation by the resident stating the teaching physician is present and was involved in the care is not sufficient to establish the teaching physician performed a face-to-face encounter.

Medicare lists the following as unacceptable documentation to indicate the teaching physician’s oversight of a resident (MCM, Chapter 12, 100.1.1.a.):
“Agree with above.,” followed by legible countersignature or identity;
“Rounded, Reviewed, Agree.,” followed by legible countersignature or identity;
“Discussed with resident. Agree.,” followed by legible countersignature or identity;
“Seen and agree.,” followed by legible countersignature or identity;
“Patient seen and evaluated.,” followed by legible countersignature or identity; and
A legible countersignature or identity alone.

For E/M services, when the physician has met the teaching physician requirements, the documentation from the resident’s note and the teaching physician’s note are combined to select the E/M code.

When a resident admits a patient to the hospital late in the night, the teaching physician can see the patient the next day and refer to the resident’s notes instead of re-documenting the services. Any changes to the patient’s condition and clinical course should be amended by the resident in his or her documentation. In this instance, the teaching physician bills for the services on the date the teaching physician sees the patient; however, both the resident’s notes and the teaching physician’s notes are still combined for the level of service.

There is an exception to the teaching physician presence for E/M services furnished in certain primary care centers. If the primary care center with a Graduate Medical Education (GME) program is granted the primary care exception, the resident may submit claims for 99201-99203, 99211–99213, G0438, and G0439 in the absence of a teaching physician. A GE modifier is appended to the code to indicate the service was provided without the presence of the teaching physician. Teaching physicians submitting claims under this exception are limited to supervision of four residents only. Specific requirements apply to this exception; see MCM, Chapter 12, 100.1.1.c."
 

jasmine.stone

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Thank you for the information danskangel313. While it is helpful, it's not quite what I'm looking for. I suspect that the clear-cut, black and white answer I want to find isn't out there, though. Again, thanks for taking the time to find that info and respond.
 
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