ED Coding and Reimbursement Alert

Question: We are debating using scribes for the residents to document.  I heard that one of the MACs had stated that residents could not use scribes because they receive GME funding for their work, which includes documentation. Is this true?  If one region disallows Medicare reimbursement for this, will the others do so?

Texas Subscriber

Answer: It is true. Although there are no documented restrictions as to who can act as a scribe, payers have expressed concern about residents or NPPs acting as scribes because of their ability to independently evaluate the patient separate from the physician and the difficulty in separating documentation performed when acting as a scribe versus documentation of services performed as a healthcare provider. If NPs or other clinical providers act as scribes, their involvement should be clearly documented.

National CMS does not have any GME payment policy on this issue so regional contractors may develop their own policy. A spokesman for the CMS carrier National Government Services recently barred teaching hospitals in one of its regions from using scribes for residents and fellows with the rationale that creation of a medical record is a key part of resident’s training and that it is paid for under graduate medical education program funding.