Indeed, the HHS Office of Inspector General (OIG) lists compliance with these guidelines in its 2004 Work Plan as an audit target for physicians, says Don White, OIG public-affairs representative.
The good news is that the AMA recognizes these E/M documentation difficulties and is taking action to rid coders of guideline frustration. "The AMA, through the CPT editorial panel, is working on improving the E/M codes so that documentation guidelines are unnecessary," says Michael Beebe, the AMA's director of CPT editorial and information services.
But until the current documentation guidelines are retired, coders must attempt to decipher them.
To access the 1995 and 1997 guidelines online, go to the CMS site http://cms.hhs.gov/medlearn/emdoc.asp. To see a chart that compares the two guideline sets, go to the same site and click "Resources."