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Medical coding resources for physicians and their staff. CodingIntel was founded by consultant and coding expert Betsy Nicoletti.

Teaching Physician and Resident Specialty | Medicare Teaching Physician Rules

Question:

Can a teaching physician from one specialty supervise a resident in a different specialty.

Answer:

Although CMS updated the rules for teaching physicians in an April 2019 transmittal, nothing in the transmittal addresses this question or changes the response below.

What does CMS say?

To answer the question, I looked in three places.

The first is Chapter 12, Sec 100 of the Medicare Claims Processing Manual.  That is where the Teaching Physician Rules are described.

Second, I looked at the MedLearn Matters booklet called “Guidelines for Teaching Physicians, Interns and Residents“.

And, finally, I found a chart that the American College of Graduate Education developed.

You won’t be shocked to hear that the question wasn’t answered directly as yes or no in any of these places, will you?

Teaching Physician:   A physician, other than an intern or resident, who involves residents in the care of his or her patients. Generally, for the service to be payable under the Medicare PFS, he or she must be present during all critical or key portions of the procedure and immediately available to furnish services during the entire service.

Scope of service

This verbiage appears repeatedly in Medicare’s guidelines.  The supervising attending physician must either be present during the key or critical portions, or in the case of some surgical procedures, not present but immediately available to furnish the service.

Although this doesn’t say that the attending and the resident must be of the exact same specialty and subspecialty, it is reasonable to assume that a general surgeon could not cover for a pediatrician and a pediatrician could not cover for a general surgeon.

I would argue that if a teaching physician is supervising a resident, he/she must have the supervised services within his or her scope of practice.  So, can a teaching physician from one specialty supervise a resident from another specialty?  Only if the teaching physician has those services within their scope of practice.

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Our mission is to provide accurate, comprehensive, up-to-date coding information, allowing medical practices to increase revenue, decrease coding denials and reduce compliance risk. That's what coding knowledge can do.

In 1988, CodingIntel.com founder Betsy Nicoletti started a Medical Services Organization for a rural hospital, supporting physician practice. She has been a self-employed consultant since 1998. She estimates that in the last 20 years her audience members number over 28,400 at in person events and webinars. She has had 2,500 meetings with clinical providers and reviewed over 43,000 medical notes. She knows what questions need answers and developed this resource to answer those questions. For more about Betsy visit www.betsynicoletti.com.