Proposed CMS interpretation creates hurdles for PA students and preceptors. We need you to submit a comment before September 10!
Less than 5 minutes of your time can removebarriers to PA education.
Earlier this year, the Centers for Medicare and Medicaid Services (CMS) amended the Medicare Claims Processing Manual to allow for teaching physician verification — rather than re-documentation — of student notes related to Evaluation and Management (E/M) services (Transmittal 3971, later replaced by Transmittal 4068).
Subsequent communications from CMS indicate that the agency believes these changes only apply to medical student documentation and not to PA student documentation.
CMS will be accepting comments on its related Physician Fee Schedule proposed rule through September 10, and we’re asking all PA education advocates to urge CMSto interpret Transmittal 4068 as also allowing teaching physicians to verify PA student documentation.You can use a pre-written comment we've prepared below or you can can create your own message. Submit your comment directly to CMSor through the PAEA Grassroots Action Network.
In addition to submitting thecomments, you are encouraged to brieflyshare your ownstory about the impact of current E/M documentation requirements on your preceptors and the value of allowing teaching physician verification of PA student documentation.
P.S. Please forward this message to any of your colleagues who care about PA education.
Here are prepared comments you can use....
Are you a Preceptor for PA students? Here is a comment you can copy and paste.
Transmittal 4068, requiring teaching physicians to re-perform student documentation of E/M services, adds a significant administrative burden that adversely impacts patient care and will impact the willingness of clinicians to train PA students.
Are you a Program Director? Here is a comment you can copy and paste.
Transmittal 4068, requiring these same actions, will likely deter preceptors from wanting to contribute to the education of PAs and NPs. There is already a severe shortfall of preceptor clinical sites, creating a roadblock to increasing enrollment in PA programs at a time when the country desperately needs clinical providers. Furthermore, the existing Medicare Claims Processing Manual definition of "student" unambiguously includes physician assistant and nurse practitioner students.
Are you a PA? Here is a comment you can copy and paste.
Transmittal 4068, which removes previous references to medical students and allows teaching physicians to verify rather than re-perform student documentation, should be interpreted to include documentation by physician assistant and nurse practitioner students (based on the Medicare Claims Processing Manual). Moreover, restricting verification of student documentation to medical students would create a two-tiered system in which preceptors would be increasingly unwilling to train physician assistant and nurse practitioner students due to additional unnecessary documentation requirements.