When did TP actually SEE the patient?
When the note is signed by the teaching physician is not so important as when the teaching physician actually saw the patient. There are many legitimate reasons for not getting a signature until the following day.
For the government payers (Medicare, Medicaid, etc), the physician must demonstrate physical presense at the bedside and participation in the services documented by the resident. For most commercial payers, any means of communication is considered "supervision" - so even if the resident just documents "discussion with Dr Teaching Physician, who agreed with plan," you can bill it.
As always, it depends on the documentation.
Hope that helps.
F Tessa Bartels, CPC, CEMC