Teaching Physicians, Interns, and Residents Guidelines Updates July 2022
This article will address the changes that CMS addressed recently for Teaching Physicians, Interns, and Residents in various settings and services provided in those settings.
Medicare will pay for services in a teaching setting based on the Medicare Physician Fee Schedule (PFS) when services are provided by a physician not a resident or when a resident provides a service and the teaching physician is present (physically or via audio/video real-time technology in a residency training site outside a Metropolitan Statistical Area (MSA).
When interpreting diagnostic radiology and other diagnostic tests in a Teaching Setting, CMS will pay for the interpretation of diagnostic radiology or other diagnostic tests under the PFS when completed by a physician. CMS will also pay the PFS rate in a residency training site when that site is outside an MSA, to a resident who interprets a diagnostic radiology and other diagnostic tests when the teaching physician is present through audio/video real-time technology. The documentation in the patient’s medical record must show that the physician took part in the interpretation of the diagnostic tests.
For psychiatric services, CMS will pay the PFS rate under an approved GME Program, with the appropriate documentation in the patient’s medical record detailing the physician’s presence through a 1-way mirror, video equipment, or similar devices.
Teaching Physician Billing Requirements are still the same except when total time decides the office or outpatient E/M visit level, when billing the only time that should be recorded is that of the teaching physician. When selecting a visit level, only count the time that the teaching physician spent doing the components of the CPT code that they are choosing for billing purposes. During a PHE, the teaching physician’s time can be included when they are present audio/video real-time technology.
The guidelines for documentation in the medical record now include the need for the teaching physician to document their physical or virtual presence in the visit, only if the residency training site is outside the MSA, and the documentation must note the services rendered during the physician’s presence through audio/video real-time technology.
Starting January 1, 2022, when you select time-based office
and or outpatient E/M visit levels, the physician may include only the time spent
doing qualifying activities, including your presence with the
residents doing those activities.
Under the primary care exception, you can’t use time to select visit level. The physician may only use Medical Decision Making (MDM) to select the E/M visit level. During COVID-19 PHE was expanded and this impacted the residents’ services list. After PHE is over, the physician can’t include visit level 4 or visit level 5 in the office setting or outpatient E/M visits in the primary care exception.
These changes that are going into effect will require a complete review by the physician and their staff members to ensure that all requirements for physician presence in a visit, interpretation, billing, and especially documentation in the patient’s medical record. When in doubt, reviewing the CMS Manual and all MLN products to help to keep the practice or organization compliant to the recent changes and current billing practices.
