CR11171 provides a change in policy by Medicare for the documentation for teaching physicians providing Evaluation and Management (E/M) services. The Medicare Learning Network (MLN) published an article on this.

It is important to train teaching physicians, residents, and nurses who document E/M services of all changes to be implemented on July 1, 2019.

To quote from the MLN article: The following provides these policy clarifications:

• For purposes of payment, E/M services billed by teaching physicians require that the medical records must demonstrate: 1) that the teaching physician performed the service or was physically present during the key or critical portions of the service when performed by the resident; and 2) the participation of the teaching physician in the management of the patient.
• The patient medical record must document the extent of the teaching physician’s participation in the review and direction of the services furnished to each beneficiary. The extent of the teaching physician’s participation may be demonstrated by the notes made by the notes in the medical records made by physicians, residents, or nurses.

What is this telling us? It is telling us a few key items.

1. The teaching physician’s participation may be documented by either the teaching physician, the resident or the nurse as of July 1, 2019. This is a loosing of the current requirements as we now may only use the teaching physician’s documentation of the participation. Documentation by the resident or the nurse of the teaching physician participation currently does not count in current documentation. But as of July 1, 2019, the resident’s and nurse’s documentation of the teaching’s physician’s participation will be able to be counted.
2. Current attestations will not be able to be used as they do not include the “extent of the teaching physician’s participation in the review and direction of the services furnished to each beneficiary.” This means that current attestations will need to be extended to include free text that is specific to the beneficiary encounter, which will be different for each beneficiary.

So, it seems while CMS gave us a little in simplifying the documentation, they also added some to complicate the attestations.

You can find the official instruction,  CR111171 issued to each MAC related to this change in documentation for teaching physician participation at the following link: https://www. cms. gov/Regulations-and-Guidance/Guidance/Transmittals/2019Downloads/R4283CP. pdf