Practice Management Alert

Plus, stick to standard CMS processes despite revalidation requests.

Medicare's teaching physician rules have long confused medical practices, but CMS aims to fix that problem but issuing several updates to its Medicare Claims Processing Manual, with Transmittal 2247.

The transmittal offers a clarification to Section 100.1.1 of the Manual, which discusses documentation instructions for E/M services performed by teaching physicians. Specifically, it addresses what the documentation must include when a resident admits a patient to a hospital late at night, but the teaching physician doesn't see the patient until later (often the next day). CMS notes that the following are required in these circumstances:

The teaching physician (TP) must document that he personally saw the patient and participated in the patient's management. He can reference the resident's note instead of re-documenting the HPI, exam, medical decision making (MDM), review of systems, and/or past, family and social history as long as the patient's condition hasn't changed and the TP agrees with the resident's note.

The TP's note must reflect changes in the patient's condition and clinical course that require that the resident's note be amended with additional information to address the patient's condition and course when the TP sees the patient.

The TP's bill must reflect the date of service that he saw the patient and his work obtaining a history, performing a physical, and participating in MDM, regardless of whether the combination of the TP's and resident's documentation satisfies criteria for a higher level of service. "For payment, the composite of the teaching physician's entry and the resident's entry together must support the medical necessity of the billed service and the level of the service billed by the teaching physician," the CMS manual notes.

To read the transmittal in its entirety, visit www.cms.gov/transmittals/downloads/R2247CP.pdf.

Submit your usual CMS enrollment changes in a timely manner, or you'll be sorry. That's the word from CMS, which is taking aim at practices that are using the revalidation process as an excuse to drag their heels about updating routine information.

"The Medicare provider enrollment revalidation effort does not change other aspects of the enrollment process," CMS says in an e-mail message to providers. "Providers should continue to submit routine changes -- address updates, reassignments, additions to practices, changes in authorized officials, information updates, etc. -- as they always have."

Even if you receive a revalidation request, you need to submit your changes separately from your revalidation information, CMS stresses.