On March 15, 2018, I had the opportunity to present on behalf of the ACS at a roundtable discussion on Capitol Hill to members of the House Ways and Means Committee on the topic of Medicare red tape relief
E/M Documentation Guidelines
The ACS has significant concerns regarding Evaluation and Management (E/M) Documentation Guidelines. Though CMS created the E/M documentation guidelines 23 years ago with the laudable goal of adding structure to the various levels of E/M services, and in an effort to create a sense of equivalency of E/M services across the multitude of specialties, ACS believes the time has come to re-examine and revise these guidelines to be more appropriate in the modern digital information era.
Again, the primary goal of all medical record documentation is to provide an accurate, chronologic record of patient care. That said, the medical record also serves other important goals including communication between providers, data exchange to facilitate clinical decisions, and a legal document. The payment-focused E/M documentation guidelines do not serve any of these objectives.
There must be some level of trust of the provider by the payers. Physicians should have the ability to meet the primary goal of the medical record without being required to repeatedly enter the same information. If a family history is recorded on Monday, there should be no requirement to re-record it on Thursday unless something cogent changes in the interim. ACS believes that documentation should focus on the minimum data elements needed to establish an accurate chronologic record of patient care.
The ACS is prepared to assist in an effort to explore ways to revise the current paper-based E/M documentation guidelines such that they more efficiently and accurately document patient care information in the modern digital era.