HCFA to Revise 1997 Documentation Guidelines

The Health Care Financing Administration has announced it will revise the 1997 documentation guidelines for evaluation and management services in response to physicians' concerns that they are complex and burdensome.  Agency officials also confirmed that the guidelines will go through a testing phase allowing input from physicians.

This announcement comes after about four months of deadlock in discussions between the agency and organized medicine.

"We are not setting a specific date to implement these guidelines," said Robert Berenson, MD, director of HCFA's Center for Health Plans and Providers.  "Instead, we are taking time to develop the guidelines, test the response and burdens, and educate physicians and Medicare carriers on revised requirements."

In the meantime, physicians can continue to use either the old guidelines or the 1997 guidelines, and carriers will recognize either for reimbursement, Berenson said.

ACEP has played a crucial role in advocating for emergency physicians during development of the documentation guidelines.  The college was one of the first groups to request a delay in implementation, which originally was set for October 1, 1997.  Since then, the guidelines have undergone a series of delays, and HCFA delayed implementation indefinitely in May.

In its comments to HCFA, ACEP sought to urge regulators to change its language concerning medical history, physical examination procedures, the definition of general multi-system examinations and other changes in order to accommodate the unique aspects of emergency medicine.

HCFA has indicated that it will use a loose framework it developed in the spring as a basis for the new revisions.  During the revisions, the American Medical Association will provide technical advice to HCFA through the CPT Editorial Panel, which will be asked to ensure that the guidelines place minimal burdens on physicians and follow CPT standards.

ACEP and other specialty societies want the guidelines to be as short and simple as possible, with definitions that are as clear and unambiguous as possible.  They also urge that HCFA should make an accomodation for inadvertent documentation errors so physicians with honest intentions will not be accused of fraud.

Although no date has been set for implementation, HCFA has hinted that a final set of guidelines could come soon, but they still would not be in time to make the 1999 CPT Book.  Also, HCFA continues to make random prepayment audits, so emergency physicians should take great care in completing their documentation regardless of which version they choose.

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