Refer to CMS Transmittal 1780. It specifically states the student may only document the ROS and PFSH and must be performed in the physical presence of a resident or teaching physician. All other documentation by the student is not applicable nor may it be countersigned or referenced as agreed with.
Consults are one of the top 5 code groups identified by CMS's CERT program for highest error percentage. (probable target for RAC)
I would not recommend billing for these under any circumstance unless the physician is willing to perform their own documentation of the HPI, exam & MDM as well as dictating the consult letter.
Hope that helps!
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