65.009 HCFA Evaluation and Management Services Documentation Guidelines


CMS Evaluation and Management Services Documentation Guidelines: The Texas Medical Association supports the following essential principles regarding the Center for Medicare & Medicaid Service’s (CMS’s) E & M documentation guidelines: (1) AMA Policy (H-330.920 and 921) should be strongly reaffirmed. That policy includes opposition to inappropriate “quantitative formulas” or assignment of “numeric values” to determine medical record keeping; unfair fraud and abuse penalties for disagreements in E & M code assignments; and repayment of “alleged Medicare overpayments” without fair due process; (2) CMS should not focus on counting methodologies or numerical formulas as the primary reason for medical record documentation. Documentation should serve the interests of good patient care and the integrity of the patient-physician relationship before any auditing or program integrity objectives are considered; (3) Focused medical review should be the sole focus of CMS audit and outlier review programs. Random audits, conducted in addition to medical reviews indicated by analysis of Medicare claims data, should not be the focus of CMS’s audit function. Such reviews are unnecessarily intrusive in physicians’ practices and are an inefficient use of taxpayer dollars; (4) Medical decision making should be emphasized much more than is presently the case in either the 1995 or 1997 “revised” guidelines; (5) Any proposed guideline that serves to criminalize the patient-physician encounter should be vigorously and thoroughly opposed (Amended CSE Rep. 13-I-98; Reaffirmed BOT Rep. 22-A-99; amended CSE Rep. 1-A-10).

Last Updated On

October 07, 2016