Medicare Compliance & Reimbursement - 2014 Issue 3
Documentation Guidelines: Those That Don't Study The Elements OF History Are Doomed To Repeat Them Under Audit
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Article Overview
This article explains common documentation issues involving the history of present illness and review of systems in evaluation and management reporting. It is aimed at coders, auditors, and clinicians who need a clearer understanding of documentation responsibilities, ROS level concepts, and payer-related considerations within CMS and CPT-based guidance.
Why This Topic Matters
History documentation is a frequent audit focus, and misunderstanding how HPI and ROS are captured can affect the supportability of E/M code selection. The article helps readers recognize the general documentation areas that create risk and where payer policies may differ.
Article Sections
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Who Can Record the HPI and ROS?
Discusses general documentation responsibility for history elements and the distinction between what different staff types may record. It also references CMS-era documentation guidance and the role of physician review.
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ROS Can Be Recorded By Ancillary Staff
Covers the role of the review of systems in the history and its use in evaluation and management documentation. The section also introduces general ROS levels and payer-related considerations tied to system review breadth.
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Verse Yourself on the Double Dip Dilemma
Addresses the broader issue of whether history elements may be drawn from multiple parts of the record and whether the same element may appear in more than one history component. It frames the topic as a documentation and audit concern.
What You Will Learn
- How HPI and ROS fit into history documentation
- Which parties may record or review history elements
- How ROS level concepts relate to E/M documentation
- Why payer policy review matters for ROS documentation
- The general issue of reusing documented history elements across sections
Who Should Read This
- Medical coders
- Coding auditors
- Physicians
- Advanced practitioners
- Clinical documentation staff
Codes Discussed
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