NAMAS Webinar Q&A: 2021 Office and Other Outpatient Visits Changes Hands-on and Q&A 12/14/2020

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Below are the questions received during our recent webinar, 2021 Office and Other Outpatient Visits ChangesHands-on and Q&A, originally presented on December 14, 2020. These questions have been answered by the webinar presenter, Pam Vanderbilt, CPC, CDEO, CPMA, CPPM, CPC-I, CEMC, CEMA, CEMA-O

Question 1:
Can you please advise if the teaching physician rule applies to fellows also or just residents?
URL Link: https://www.cms.gov/newsroom/fact-sheet ... dar-year-1
On the teaching supervision of evaluation and management during the Public Health Emergency, excluding telephone that does not also include video. I’ve also attached the most recent update from Medicare on office/outpatient Evaluation and Management visits for your reference.
• CMS confirmed that under the primary care exception, the attending may supervise the service using audio/visual communication during the public health emergency, not audio only
• CMS is allowing an attending to be present via real-time audio/visual communication in supervising an E/M service provided by a resident. The teaching physician must be present for the key/critical components using audio/visual communication. Phone is insufficient.
• CMS documentation clarification:
o “must clearly reflect how and when the teaching physician was present during the key portions of the service, in accordance with our regulations.”
• CMS final rule is that direct supervision may be provided using real-time, interactive audio and video technology through the later of the end of the calendar year in which the PHE ends or December 31, 2021
Answer 1:
This is a great question! To answer it, I would refer you to the Medicare IOM at https://www.cms.gov/Regulations-and-Gui ... 104c12.pdf.
“100 - Teaching Physician Services (Rev. 811, Issued: 01-13-06, Effective: 01-01-06, Implementation: 02-13-06) Definitions For purposes of this section, the following definitions apply.
Resident - An individual who participates in an approved graduate medical education (GME) program or a physician who is not in an approved GME program but who is authorized to practice only in a hospital setting. The term includes interns and fellows in GME programs recognized as approved for purposes of direct GME payments made by the FI. Receiving a staff or faculty appointment or participating in a fellowship does not by itself alter the status of "resident". Additionally, this status remains unaffected regardless of whether a hospital includes the physician in its full time equivalency count of residents.”
Based on this definition, I expect the same supervision requirements apply to a fellow under these circumstances as for a resident.
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