Teaching Physician – Primary Care Exception

CMS updated the teaching physician rules in 2019, and this article reflects the change. On April 26, 2019 CMS released Transmittal 4283. The transmittal primarily addresses E/M services, but also amends the section of the manual related to the primary care exception.  The changes to the primary care section were mostly wording updates.

Those rules are explained in the this article. For additional information, see the CodingIntel guide to Teaching Physician Rules.

CodingIntel members can also download the Teaching Physician quick reference guide.

Primary Care Exception

This primary care exception allows residents who have been in residency for longer than six months to see patients in a primary care practice under the supervision of the attending, but without the requirement that the attending see each patient.  The primary care center must attest in writing that it meets the requirements.

• The teaching physician may only supervise four or fewer residents at a time and must be immediately available to provide assistance.
• The teaching physician may not have other responsibilities at that time and must have primary responsibility for those patients treated by the residents in the primary care program.
• The teaching physician must document the extent of his or her participation in the review and care of the services.
• The teaching physician must review care provided during or immediately after the patient is seen.
• The April 2019 transmittal that updated E/M services added this statement.

“The patient medical record must document the extent of the teaching physician’s participation in the review and direction of the services furnished to each beneficiary. The extent of the teaching physician’s participation may be demonstrated by the notes in the medical records made by physicians, residents, or nurses.”

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