Developing: CMS allows Student Documentation – Happy Days at Academic Medical Centers

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Original story posted on: February 7, 2018

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     by Dr. Ronald Hirsch
    Thursday, February 8, 2018 
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A quietly introduced rule change should relieve burden on teaching physicians. 

How many weeks has it been since I have been critical of the Centers for Medicare & Medicaid Services (CMS)?

Probably not too many. Usually it’s about unclear guidance or a missing document. In fact, I could point out that CMS sent out a press release about the new advance beneficiary notice (ABN) for use at skilled nursing facilities (SNFs), but they forgot to post the actual ABN until the next day. But I’m not going to criticize them for that.

Instead, I have to scold them for not publicizing something that they should have been shouting from the rooftops, something one physician on Twitter called a game-changer for academic medicine.

Now, if you are at a health system with no medical students, go ahead and go on to the next article, since this does not affect you. But for those who do have medical students, CMS has issued a manual change, effective March 5, which will allow teaching physicians to use documentation created by medical students.

Right now, the regulation governing medical student documentation reads as so: “the teaching physician may not refer to a student’s documentation of physical exam findings or medical decision-making in his or her personal note. If the medical student documents evaluation and management (E&M) services, the teaching physician must verify and re-document the history of present illness, as well as perform and re-document the physical exam and medical decision-making activities of the service.”

What does that mean? Well, much of what medical students document is good for their education, and practicing documentation certainly makes perfect (as long as it is not practicing how to copy and paste). Furthermore, the family history, social history, and review of systems documented by a student can be used by the teaching physician, but everything else is basically disregarded. The physician must repeat every element and document it all themselves.

But with this change to the regulation, while the teaching physician must of course verify all the information in the medical student’s notes and must perform the physical examination and the medical decision-making, they no longer have to re-document all these elements. They can simply indicate in the record that they verified the medical student’s documentation, and of course made any corrections or additions appropriate.

When I shared this with one of my physician advisor buddies at a 475-bed academic medical center, she was speechless. Perhaps it was because she was thinking about how, as an attending physician on the teaching service, she had written thousands of those notes, and they finally went and changed the rule now that she has more administrative duties and fewer teaching responsibilities. Still, it will greatly reduce the paperwork burden on her colleagues.

Now of course, you need to determine how this will be implemented at your facility, so you can get the transmittal, titled change request 10412, transmittal 3971, by clicking here.

Ronald Hirsch, MD, FACP, CHCQM

Ronald Hirsch, MD, FACP, CHCQM is vice president of the Regulations and Education Group at R1 Physician Advisory Services. Dr. Hirsch’s career in medicine includes many clinical leadership roles at healthcare organizations ranging from acute-care hospitals and home health agencies to long-term care facilities and group medical practices. In addition to serving as a medical director of case management and medical necessity reviewer throughout his career, Dr. Hirsch has delivered numerous peer lectures on case management best practices and is a published author on the topic. He is a member of the Advisory Board of the American College of Physician Advisors, a member of the American Case Management Association, and a Fellow of the American College of Physicians. Dr. Hirsch is a member of the RACmonitor editorial board and is regular panelist on Monitor Mondays.

The opinions expressed are those of the author and do not necessarily reflect the views, policies, or opinions of R1 RCM, Inc. or R1 Physician Advisory Services (R1 PAS).

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