Wiki Unable to obtain ROS

[kat70959]

The MAC for my area is Novitas, a co worker and myself are interpreting some guidelines differently and I would like some other opinions.
the provider has 3 elements of the HPI, 1 history the patients past illnesses, and a statement that the ROS can't be obtained due to the patients mental state.
I have the HPI as EPF with full credit given for the ROS, she gave it a COMP. her reasoning is that the statement about not being able to obtain ROS due to mental state automatically gives the whole HPI COMP status.

Am I reading the guidelines incorrectly?

 

[smoore123]

This is directly from the Novitas FAQ's:

11. When a physician performs an E/M service and the patient is not able to provide history, if the physician documents “patient in a coma,” “patient not able to respond,” “patient unresponsive,” can they count a comprehensive history?

When a physician performs an E/M service and is unable to obtain parts of the history component for that encounter, documentation should clearly reflect the components that were not obtained (HPI, ROS and/or PFSH). Documentation should also include why the components were not obtained (patient unresponsive, sedate on a vent, etc.), and attempts to obtain information from other sources; such as a family member, spouse, nurse, etc. When the Clinical Reviewers are reviewing documentation, it is reviewed in its entirety. If the documentation clearly supports that the patient is not able to provide the information necessary (history components) and attempts were made to obtain the history from other sources, a comprehensive history level may be credited.

The ROS statement alone does not give a comprehensive history. If the documentation is supportive as to why HPI and other history elements including ROS and PFSH could not be obtained then a comprehensive history could be given credit.