Coding Guide – Teaching Physician Rules

The teaching physician rules are Medicare rules that allow for payment for services that are performed jointly between a resident and a licensed attending physician (the teaching physician). This is a high-risk area in compliance, so be sure to read the fine print if you’re submitting claims.

CMS updated the rules regarding student documentation in 2018 and updated the E/M rules in 2019. This guide reflects both sets of changes.

In 2020, CMS updated documentation requirements for nurse practitioner students and physician assistant students. This guide reflects the changes made in 2018, 2019 and 2020 The 2021 Physician Fee Schedule Final Rule clarified that if time is used to select and E/M service, count only the attending physician’s time, not the resident’s time. This clarification was not a change in policy.

The level of participation, who must document the participation, and the required documentation differ based on the type of service that is performed. But whatever the medical service, there must be documentation of the attending’s participation in the care of the patient. This is an area of high compliance risk and academic practices need to educate and re-educate with every new group of residents and recently hired attending physician.

The updated version of this billing guide starts with a quick reference sheet.

The Medicare manual has specific definitions related to the teaching physician rule. At the end of this billing guide, there are two CMS citations for readers who want to read more .

Table of Contents

• Quick reference sheet
• Teaching physician rules
• Change relating to medical student services
• E/M services
• Primary care exception
• Telehealth
• Surgical services
• Modifiers
• Critical care
• Psychiatry servcies
• CMS resources

For additional resources, see teaching physician articles and tips which include a quick reference reference sheet, and

Review the complete Medicare Guidelines

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