(Medicare Claims Processing Manual)

 Comprehensive care not limited by organ system or  diagnosis.  Residency programs most likely qualifying for this exception include family practice, general internal medicine, geriatric medicine, pediatrics, and obstetrics/gynecology.   Certain GME programs in psychiatry may qualify in special situations such as when the program furnishes comprehensive care for chronically mentally ill patients. These would be centers in which the range of services the residents are trained to furnish, and actually do furnish, include comprehensive medical care as well as psychiatric care. For example, antibiotics are being prescribed as well as psychotropic drugs.   The patient medical record must document the extent of the teaching physicians participation in the review and direction of the services furnished to each beneficiary.  The extent of the teaching physicians participation may be demonstrated by the notes in the medical records made by physicians, residents, or nurses.   100.1.2 - Surgical Procedures  (Rev. 2303, Issued: 09- 14-11, Effective: 06 -01-11, Implementation: 07- 26-11)  In order to bill for surgical, high- risk, or other complex procedures, the teaching physician must be present during all critical and key portions of the procedure and be immediately available to furnish services during the entire procedure.   A. Surgery (Including Endoscopic Operations)   The teaching surgeon is responsible for the preoperative, operative, and postoperative care of the beneficiary.  The teaching physicians presence is not required during the opening and closing of the surgical field unless these activities are considered t o be critical or key portions of the procedure.  The teaching surgeon determines which postoperative visits are considered key or critical and require his or her presence.  If the postoperative period extends beyond the patients discharge and the teaching surgeon is not providing the patients follow -up care, then instructions on billing for less than the global package in 40 apply.  During non- critical or non -key portions of the surgery, if the teaching surgeon is not physically present, he/she must be i mmediately available to return to the procedure, i.e., he/she cannot be performing another procedure.  If circumstances prevent a teaching physician from being immediately available, then he/she must arrange for another qualified surgeon to be immediately available to assist with the procedure, if needed.   1. Single Surgery   When the teaching surgeon is present for the entire surgery, his or her presence may be demonstrated by notes in the medical records made by the physician, resident, or operating room nurse.  For purposes of this teaching physician policy, there is no required information that the teaching surgeon must enter into the medical records.   2. Two Overlapping Surgeries   In order to bill Medicare for two overlapping surgeries, the teaching surgeon must be present during the critical or key portions of both operations.  Therefore, the critical or key portions may not take place at the same time.  When all of the key portions of the initial procedure have been completed, the teaching surgeon may begin to become involved in a second procedure.  The teaching surgeon must personally document in the medical record that he/she was physically present during the critical or key port ion(s) of both procedures.  When a teaching physician is not present during non- critical or non -key portions of the procedure and is participating in another surgical procedure, he/she must arrange for another qualified surgeon to immediately assist the re sident in the other case should the need arise.  In the case of three concurrent surgical procedures, the role of the teaching surgeon (but not anesthesiologist) in each of the cases is classified as a supervisory service to the hospital rather than a phys ician service to an individual patient and is not payable under the physician fee schedule.  3. Minor Procedures   For procedures that take only a few minutes (five minutes or less) to complete, e.g., simple suture, and involve relatively little decision making once the need for the operation is determined, the teaching surgeon must be present for the entire procedure in order to bill for the procedure.   4. Anesthesia   Medicare pays at the regular fee schedule level if a teaching anesthesiologist is involved in a single procedure with one resident.  The teaching physician must document in the medical records that he/she was present during all critical (or key) portions of the procedure.  The teaching physicians physical presence during only the preoperative or postoperative visits with the beneficiary is not sufficient to receive Medicare payment. If an anesthesiologist is involved in concurrent procedures with more than one resident or with a resident and a nonphysician anesthetist and the service is furnished prior to January 1, 2010, Medicare pays for the anesthesiologists services as medical direction.   In those cases where the teaching anesthesiologist is involved in two concurrent anesthesia cases with residents on or after January 1, 2004, the teaching anesthesiologist may bill the usual base units and anesthesia time for the amount of time he/she is p resent with the resident.  The teaching anesthesiologist can bill base units if he/she is present with the resident throughout pre and post anesthesia care.  The teaching anesthesiologist should use the AA modifier to report such cases.  The teaching ane sthesiologist must document his/her involvement in cases with residents.  The documentation must be sufficient to support the payment of the fee and available for review upon request.   For anesthesia services furnished on or after January 1, 2010, payment may be made under the Medicare physician fee schedule at the regular fee schedule level if the teaching anesthesiologist is involved in the training of a resident in a single anesthesia  case, two concurrent anesthesia cases involving residents, or a single anesthesia case involving a resident that is concurrent to another case paid under the medical direction rules.  To qualify for payment, the teaching anesthesiologist, or different anesthesiologists in the same anesthesia group, must be present during all critical or key portions of the anesthesia service or procedure involved.  The teaching anesthesiologist (or another  anesthesiologist with whom the teaching physician has entered into an arrangement) must be immediately available to furnish anesthesia services during the entire procedure.  The documentation in the patients medical records must indicate the teaching physicians presence during all critical or key portions of the anesthesia procedure and the immediate availability of another teaching anesthesiologist as necessary.   If different teaching anesthesiologists are present with the resident during the key or critical periods of the resident case, the NPI of the teaching anesthesiologist who started the case must be indicated in the appropriate field on the claim form.   The teaching anesthesiologist should use the AA modifier and the GC certification modifier to report such cases.  See 50 B. and 0 K.  5. Endoscopy Procedures   To bill Medicare for endoscopic procedures (excluding endoscopic surgery that follows the surgery policy in subsection A, above), the teaching physician must be present during the entire viewing.  The entire viewing starts at the time of insertion of the endoscope and ends at the time of removal of the endoscope.  Viewing of the entire procedure through a monitor in another room does not meet the teaching physician presence requirement.  6. Interpretation of Diagnostic Radiology and Other Diagnostic Tests   Medicare pays for the interpretation of diagnostic radiology and other diagnostic tests if the interpretation is performed by or reviewed with a teaching physician.  If the teaching physicians signature is the only signature on the interpretation, Medicar e assumes that he/she is indicating that he/she personally performed the interpretation.  If a resident prepares and signs the interpretation, the teaching physician must indicate that he/she has personally reviewed the image and the residents interpretat ion and either agrees with it or edits the findings.  Medicare does not pay for an interpretation if the teaching physician only countersigns the residents interpretation.  100.1.3 - Psychiatry  (Rev. 811, Issued: 01- 13-06, Effective: 01 -01-06, Implementation: 02- 13-06)  The general teaching physician policy set forth in 100.1 applies to psychiatric services.  For certain  psychiatric services, the requirement for the presence of the teaching physician during the service may be met by concurrent observation of the service by use of a one -way mirror or video equipment.  Audio- only equipment does not satisfy to the physical pr esence requirement.  In the case of time -based services such as individual medical psychotherapy, see 100.1.4, below.  Further, the teaching physician supervising the resident must be a physician, i.e., the Medicare teaching physician policy does not apply to psychologists who supervise psychiatry residents in approved GME programs.  100.1.4 - Time -Based Codes  (Rev. 11288; Issued: 03- 04-22; Effective: 01 -01-22; Implementation: 02 -15-22)  For procedure codes determined on the basis of time, the teaching physician must be present for the period of time for which the claim is made.  For example, a code that specifically describes a service of from 20 to 30 minutes may be paid only if the teac hing physician is physically present for 20 to 30 minutes.  Do not add time spent by the resident in the absence of the teaching physician to time spent by the resident and teaching physician with the beneficiary or time spent by the teaching physician alone with the beneficiary.  Examples of codes falling into this category include:    Individual medical psychotherapy (HCPCS codes 90804 -  90829);    Critical care services (CPT codes 99291 -99292);    Hospital discharge day management (CPT codes 99238- 99239);   E/M codes in which counseling and/or coordination of care dominates (more than 50 percent) of the encounter, and time is considered the key or controlling factor to qualify for a particular level of E/M service;    Office/outpatient E/M visit codes for which total time is used for the visit level selection.  For purposes of selecting visit level, only count time spent by the teaching physician performing qualifying activities listed by CPT (with or without direct pat ient contact on the date of the encounter), including the time the teaching physician is present when the resident is performing such activities;    Prolonged services (CPT codes 99358- 99359); and   Care plan oversight (HCPCS codes G0181 -  G0182).  100.1.5 - Other Complex or High -Risk Procedures  (Rev. 1, 10- 01-03)  In the case of complex or high- risk procedures for which national Medicare policy,  local policy, or the CPT description indicate that the procedure requires personal (in person) supervision of its performance by a physician, pay for the physician services associated with the procedure only when the teaching physician is present with the resident.  The presence of the resident alone would not establish a basis for fee schedule payment for such services.  These procedures include interventi onal radiologic and cardiologic supervision and interpretation codes, cardiac catheterization, cardiovascular stress tests, and trans -esophageal echocardiography.   100.1.6 - Miscellaneous  (Rev. 1458, Issued: 02- 22-08, Effective: 03 -24-08, Implementation: 03- 24-08)  In the case of maternity services furnished to women who are eligible for Medicare, apply the physician presence requirement for both types of delivery as A/B MACs (B) would for surgery.  In order to bill for the procedure, the teaching physician must be present for the delivery.  These procedure codes are somewhat different from other surgery codes in that there are separate codes for global obstetrical care (prepartum, delivery, and postpartum) and for deliveries only.  In situations in which the teaching physicians only involvement was at the time of delivery, the teaching physician should bill the delivery only code.  In order to bill for the global procedures, the teaching physician must be present for the minimum indicated number of  visits when such a number is specified in the description of the code.  This policy differs from the policy on general surgical procedures under which the teaching physician is not required to be present for a specified number of visits.  In the case of end stage renal related visits furnished under the monthly capitation payment method (MCP), the physician presence policy as discussed in 100.1 applies.  Patient visits furnished by residents may be counted toward the MCP visits if the teac hing MCP physician is physically present during the visit. The teaching physician may utilize the residents notes, however the teaching physician must document his or her physical presence during the visit(s) furnished by the resident and that he or she r eviewed the residents notes.  The teaching physician could document these criteria as part of an extensive once a month MCP note.   100.1.7 - Assistants at Surgery in Teaching Hospitals  (Rev. 811, Issued: 01- 13-06, Effective: 01 -01-06, Implementation: 02- 13-06)  A. General   A/B MACs (B) do not pay for the services of assistants at surgery furnished in a teaching hospital which has a training program related to the medical specialty required for the surgical procedure and has a qualified resident available to perform the servi ce unless the requirements of one of subsections C, D, or E are met. Each teaching hospital has a different situation concerning numbers of residents, qualifications of residents, duties of residents, and types of surgeries performed.