Teaching Physician Services: 2022 Changes
Teaching physician services refers to physicians teaching interns, residents, and medical students during patient treatment. The Centers for Medicare & Medicaid Services (CMS) outlines the regulations associated with these services and the requirements for maintaining compliance with the regulations in the Medicare Claims Processing Manual, Chapter 12. If you submit claims as a teaching physician, it is your responsibility to know and adhere to these rules. The Medicare Claims Processing Manual, Chapter 12 contains the Calendar year 2022 changes to Medicare Part B Payment Policies Final Rule (CMS-1751-F). E/M visit billing information for teaching physicians has been updated.
Key Changes
|
IOM 100-04, Chap. 12 |
General Category |
Things to Know |
|---|---|---|
|
Section 100.1.1 |
Exception for E/M Services Furnished in Certain Primary Care Centers |
Effective January 1, 2022, teaching physicians may use only medical decision making (MDM) for purposes of E/M visit level selection when billing the Medicare program under the physician fee schedule for office/outpatient E/M visits under this primary care exception. |
|
Section 100.1.4 |
Timed-Based Codes |
Office/outpatient E/M visit codes for which total time is used for the visit level selection. For purposes of selecting visit level, only count time spent by the teaching physician performing qualifying activities listed by CPT (with or without direct patient contact on the date of the encounter), including the time the teaching physician is present when the resident is performing such activities. |
When billing E/M services as a teaching physician you must personally document, at a minimum, the following:
- That you performed the service or were physically present during the key or critical portions of the service when performed by the resident; and
- Your participation in the management of the patient
This may be supported by entries in the medical record made by the students, residents, nurses or the teaching physician. However, the teaching physician must verify in the medical record all student documentation or findings. Also, the teaching physician must personally perform (or reperform) the physical exam and medical decision making activities of the E/M service being billed, but verification of student documentation in the medical record is allowed, rather than redocumenting this work.
Exception for E/M Services Furnished in Certain Primary Care Centers
When providing E/M services under a program (GME) granted a primary care exception, teaching physicians may bill Medicare for certain E/M services provided by residents. However, effective January 1, 2022, teaching physicians must use medical decision making (MDM) for purposes of E/M visit level selection when billing the Medicare program under the physician fee schedule for office/outpatient E/M visits under this primary care exception.
Under this exception, teaching physicians may submit claims for services furnished by residents in the absence of a teaching physician for the following services:
|
New Patient |
Established Patient |
|
99202 |
99211 |
|
99203 |
99212 |
|
|
99213 |
Also included under the primary care exception are HCPCS codes G0402, G0438 and G0439. Residents providing the billable patient care service without the physical presence of a teaching physician must have completed at least six months of a GME approved residency program. Teaching physicians submitting claims under this exception may not supervise more than four residents at any given time and must direct the care from a proximity that enables immediate availability.
For procedure codes determined on the basis of time, the teaching physician must be present for the period of time for which the claim is made. For services in this category, do not add time spent by the resident in the absence of the teaching physician. For E/M codes in which counseling and/or coordination of care comprises more than 50 percent of the encounter, and time is considered the key or controlling factor to qualify for a particular level of E/M service, only count time spent by the teaching physician performing qualifying activities, including the time the teaching physician is present when the resident is performing such activities.
For more information on the requirements and restrictions of the Primary Care Exemption, refer to 42 CFR 413.78(e)(3)(ii), 42 CFR 413.79(a)(6) and Publication 100-04 Medicare Claims Processing Manual, Chapter 12, Section 100.1.1.
References