tci Medicare Compliance & Reimbursement - 2014 Issue 21
Part B Documentation: Heed This MAC Tip on Documentation by Ancillary Staff
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Article Overview
This article reviews Medicare contractor guidance on who may document different parts of an evaluation and management record and how that documentation should be treated. It is aimed at physicians, nonphysician practitioners, coders, and practice staff who need to understand documentation roles, record integrity, and related payer expectations. The discussion also compares ancillary staff documentation with scribe arrangements and highlights contractor-specific policy statements.
Why This Topic Matters
Documentation responsibilities can affect whether an E/M service is supported in the medical record and whether billing under a physician’s identifier is appropriate. Understanding these distinctions helps practices reduce claim risk and align recordkeeping with Medicare contractor guidance.
Article Sections
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Ancillary staff documentation and physician responsibility
This section summarizes the Medicare guidance on the parts of the medical record that may be documented by ancillary staff versus the parts expected from the treating clinician. It also addresses how preliminary information should be treated in the record.
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What about scribes?
This section explains the general concept of scribes and how that arrangement differs from other types of documentation activity in a patient encounter. It also notes related billing and record-creation considerations described by the contractor guidance.
What You Will Learn
- How Medicare contractor guidance distinguishes ancillary staff documentation from clinician documentation
- How scribe documentation differs from patient-reported documentation
- Why documentation roles matter for E/M record support and billing alignment
- How contractor guidance addresses physician and nonphysician practitioner record responsibilities
Who Should Read This
- Physicians
- Nonphysician practitioners
- Medical coders
- Billers
- Practice administrators
- Clinical documentation staff
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