From Part B News, 6/11/07 issue:
In an email to Part B News, CMS confirmed that the strong guidance to that effect recently posted on Noridian’s website was, in fact, official agency policy.
Noridian instructed physicians in the carrier’s 13 states that “reviewing information obtained by ancillary staff and writing a declarative sentence does not suffice for the [HPI]. An example of unacceptable HPI documentation would be “I have reviewed the HPI and agree with above.” The Noridian posting echoes recently published guidance
from Palmetto GBA and Wisconsin Physician Services, as several readers pointed out.
“The Noridian [Web site] is correct,” a CMS official wrote in response to a Part B News request for confirmation.
Specific allowance is made for individuals other than the billing provider to obtain and document the ROS and PFSH subcomponents of History. In the '97 guidelines, allowance is made for ancillary staff to obtain and document the vitals (with virtually all Medicare carriers allowing this when '95 guidelines are used as well).
This is mentioned in the 10/24/05 Part B News, where it says:
"The entire set of guidelines were written to identify the physician work [emphasis added] necessary to perform and document" the medical record for an E/M service, an E/M guru from CMS tells Part B News. The official says those are - as Buechner points out - ROS, PFSH and vitals."
So unless the guidelines specifically allow someone else to do something, the work they describe is understood to be physician work only.
Think about it. The Guidelines already say that it's ok for ancillary staff to perform the ROS and PFSH components. If they are also allowed to take both the CC and HPI, then the doctors would be completely removed from history-taking, other than writing a short note saying that they reviewed what history a nurse took. Many doctors say that the history is the most important part of a visit. There is no way that permission will be given for ancillary staff to do all of it, and this permission wasn't given in the guidelines.
Seth Canterbury, CPC, ACS-EM