Quality

Documentation, CMS-Approved Language Key to Getting Paid for Hospitalist Teaching Services

Additionally, scribing the attestation is not permitted. Residents cannot document the teaching physician attestation on behalf of the physician under any circumstance. CMS rules require the teaching physician to document their presence, participation, and management of the patient. In an EHR, the teaching physician must document this entry under his/her own log-in and password, which is not to be shared with anyone.

Students

CMS defines student as “an individual who participates in an accredited educational program [e.g. a medical school] that is not an approved GME program.”1 A student is not regarded as a “physician in training,” and the service is not eligible for reimbursement consideration under the teaching physician rules.

Per CMS guidelines, students can document services in the medical record, but the teaching physician may only refer to the student’s systems review and past/family/social history entries. The teaching physician must verify and redocument the history of present illness. A student’s physical exam findings or medical decision-making are not suitable for tethering, and the teaching physician must personally perform and redocument the physical exam and medical decision-making. The visit level reflects only the teaching physician’s personally performed and documented service.

Carol Pohlig is a billing and coding expert with the University of Pennsylvania Medical Center, Philadelphia. She is also on the faculty of SHM’s inpatient coding course.

Resident Reminders

Overnight admissions

When patient is admitted at night, a resident may care for the patient until the teaching physician is able to see the patient on the following calendar day. The teaching physician can still bill for an admission service under the following criteria:3

  • The teaching physician must document that they personally saw the patient and participated in the management of the patient. The teaching physician may reference the resident’s note in lieu of redocumenting the history of present illness, exam, medical decision-making, review of systems, and/or past family/ social history, provided that the patient’s condition has not changed and the teaching physician agrees with the resident’s note.
  • The teaching physician’s note must reflect changes in the patient’s condition and clinical course that require that the resident’s note be amended with further information to address the patient’s condition and course at the time the patient is seen personally by the teaching physician.
  • The visit level is based on cumulative documentation from the resident and the teaching physician. However, the service date on the claim must reflect the date that the teaching physician actually saw the patient, and not the previous date of the resident encounter.

Moonlighting

Some residents are hired by a facility to perform “moonlighting” services. These medical and/or surgical services are not related to their training program and can be covered as physician services. When performed in a facility different from their training facility, the services are covered if:4

  • The services are identifiable physician services, the nature of which requires performance by a physician in person and which contribute to the diagnosis or treatment of the patient’s condition; and
  • The intern or resident is fully licensed to practice medicine, osteopathy, dentistry, or podiatry by the state in which the services are performed.

If the services are performed within the resident’s training facility, the services are covered if they meet the above criteria and the services performed can be separately identified from those services that are required as part of the training program.4

—Carol Pohlig

References

  1. Centers for Medicare and Medicaid Services. Guidelines for Teaching Physicians, Interns, Residents. CMS website. Available at: http://www.cms.gov/MLNProducts/downloads/gdelinesteachgresfctsht.pdf. Accessed Jan. 8, 2013.
  2. Abraham M, Ahlman J, Anderson C, Boudreau A, Connelly J. Current Procedural Terminology 2012 Professional Edition. Chicago: American Medical Association Press; 2011.
  3. Centers for Medicare and Medicaid Services. Medicare Claims Processing Manual: Chapter 12, Section 100. CMS website. Available at: http://www.cms.hhs.gov/manuals/downloads/clm104c12.pdf. Accessed Jan. 8, 2013.
  4. Centers for Medicare and Medicaid Services. Medicare Benefit Policy Manual: Chapter 15, Section 30.2. CMS website. Available at: http://www.cms.hhs.gov/manuals/Downloads/bp102c15.pdf. Accessed Jan. 8, 2013.
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