The Centers for Medicare and Medicaid Services (CMS) guidelines for Teaching Physicians, Interns and Residents (2017) are specifically directed to the role of the teaching physician, although
they can be applied to teaching nurse practitioners who care for Medicare patients. The CMS guidelines and NTF criteria for the ratio of preceptor to student are reasonable and explicitly state: As an expert clinical practitioner, the preceptor has mastered a variety of ways of
thinking that contribute to the process of clinical reasoning. Teaching the student how to use these ways of thinking helps. The process of teaching clinical reasoning guides the student in learning new ways of thinking in clinical practice. Students should be asked to: 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
When billing E/M services as a teaching physician you must personally document, at a minimum, the following:
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 Under this exception, teaching physicians may submit claims for services furnished by residents in the absence of a teaching physician for the following services:
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
Can you bill for residents?You can't bill for the resident, but you can bill for the provider with GC modifier.. ONLY if the teaching physician is physically present during the critical or key portions of the service. CMS has a guide/fact sheet under the Medicare Learning Network called Guidelines for teaching physicians, interns, and resident.
What modifier is used for residents?A GC Modifier is a modifier added to a CPT code for service(s) performed in part by a resident under the direction of a teaching physician (TP). When should the GC modifier be used? A GC Modifier is used when a resident, under the direction of a teaching physician, is involved in the management and care of a patient.
What is the GE modifier?Modifiers GC and GE are used to identify the involvement of a resident in the care of the patient. These modifiers should be used on Medicare and Medicaid patients whenever a resident is involved in the care provided.
What is the primary care exception?Under the primary care exception, in certain teaching hospital primary care centers, teaching physicians can bill certain services residents provide independently without teaching physicians present, but the teaching physicians must review the care.
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Cms guidelines for teaching physicians interns and residents
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