It depends what type of fellow you have.
There are fellows that are actually hired as staff, faculty, jr. faculty, etc. In the eyes of the insurance, they are attendings just like the more senior physician. The notes could be added together and billed out under one E/M service and thus the senior's ID #.
If however, the fellow is through some sort of program (residency, GME, etc.) he/she would be considered a resident in the eyes of the insurance company and a teaching physician attestation would be needed in order to use the note. The the senior MD would also add the history, exam, and MDM elements that he/she did/found.
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