Memorandum from Department of Health & Human Services, Health Care Financing Administration Date: June 30, 1997 From: Acting Director Office of Benefits Integrity, BPO Subject: Documentation Guidelines for Evaluation and Management Services for Physician Services - ACTION To: All Associate Regional Administrators for Medicare This memorandum concerns the latest revisions to the Documentation Guidelines for Evaluation and Management Services. The changes and additions include the following: - the content of general multi-system examinations had been defined with greater clinical specificity - documentation requirements for general multi-system examinations have been changed - content and documentation requirements have been defined for examinations pertaining to ten organ systems - several editorial changes have been made in the definition of the four types of exams - the definition of an extended history of present illness has been expanded to include chronic or inactive conditions. Please send the attached guidelines to all Contractors (both intermediaries and carriers) in your regions. Instruct contractors to inform providers in their next bulletin that these guidelines are available on the American Medical Association (AMA) bulletin board, the HCFA Web page and through the specialty societies. Encourage contractors to publish these guidelines if possible. These guidelines are not subject to the AMA copyright rules. The bulletins should also inform physicians that if they are unable to obtain these guidelines through these means the guidelines can be obtained from the contractor. While these guidelines will be effective October 1, 1997, contractors should also inform providers that there will be a grace period between October 1, 1997 and January 1, 1998 during which providers can document Evaluation and Management services in accordance with the current guidelines or the revised ones. The AMA and specialty societies will be working cooperatively to facilitate training. Instruct contractors to continue working with the specialty societies in educating the provider community. However, contractors may provide training on an "as needed basis." Remind contractors of the following: - the documentation guidelines developed jointly by HCFA and the AMA represent HCFA policy regarding interpretation of the E/M codes in CPT and the medical record documentation that is required to support a given level of code. The documentation guidelines are considered instructional material from HCFA. - reviewers must request all material in the medical record which would support the level of service reported. This includes not only the progress note itself but such things as separate order sheets for tests, patient completed history forms, etc. - reviewers must look through the entire record they receive and "give credit" for whatever they can find, regardless of how the record is organized. - corrective action may include requiring additional documentation, beyond that indicated in the documentation guidelines. If, for example, a carrier concludes a physician is abusing the rules on documenting and reporting encounters dominated by counseling, documentation of the time spent counseling as well as the total time may be required. If you or your staff have any questions, please contact Linda Easter, of my staff at (410) 786-6978. Marjorie Kanof, M.D. Memorandum from Department of Health & Human Services, Health Care Financing Administration