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The Primary Care Exception (PCE) allows teaching physicians to bill for certain evaluation and management (E/M) services without direct supervision of a resident, provided specific requirements are met. While this exception can streamline workflow and improve access to care in primary care settings, misunderstanding or misapplying the rules can result in compliance risk and lost reimbursement. This session provides a practical and thorough review of the CMS PCE guidelines.

Attendees will gain insight into when and how the exception can be applied, what documentation must be present, and how to distinguish between services that qualify under the exception versus those that require standard supervision. We’ll also explore how to integrate this exception into compliant workflows and maximize reimbursement opportunities for teaching physicians.

Learning Objectives/Agenda

• Define the CMS Primary Care Exception and identify the services that qualify under it
• Understand the supervision and documentation requirements specific to the exception
• Differentiate between services billable under the PCE and those requiring direct physician involvement
• Recognize common compliance pitfalls and audit risks related to the exception
• Apply the Primary Care Exception to real-world scenarios and workflow integration

Why is this topic important?

With increased scrutiny from payers and the OIG on teaching physician billing practices, ensuring proper application of the Primary Care Exception is critical. As academic medical centers and residency programs face growing patient volumes and staffing shortages, the PCE offers a valuable tool—but only if applied correctly. This session will help ensure organizations avoid costly errors while optimizing compliant revenue capture.

Who would benefit from this topic?

• Teaching Physicians and Residents
• Compliance Officers
• Medical Coders
• Auditors
• Practice Managers
• Billing and Coding Managers

What is the presenter's background/expertise on this topic?

As a nationally recognized expert in Evaluation and Management (E/M) coding and auditing, Jacob has conducted numerous audits and educational sessions for academic medical centers and residency programs. He specializes in Medicare compliance and have advised organizations on appropriate implementation of the Primary Care Exception, including policy review, workflow optimization, and documentation training. His background includes serving on national healthcare advisory boards and leading regulatory compliance initiatives across multiple states and provider types.

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