Established visits are scored on two of three elements. And so, a ROS is not an absolute requirement. It is possible to score based on the level of Exam and the level of the Medical Decision Making, if the History doesn't support the level.
It is, however, good practice, in most cases, to document a Review of Systems, for at least the system wherein the patient's complaint(s) are found.
In my experience, the ROS questions are generally asked, but may not be documented if the provider doesn't find the answers to his/her questions to be significant. But, they should document, for lots of reasons, that the questions were asked, and how they were answered.
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