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September 19, 2013 - Updated 05.07.19

Teaching Physician Services: Supervision, Documentation, and HCPCS Modifier GC

The purpose of this article is to clarify the requirements for and documentation of teaching physician involvement in these services. Submit HCPCS modifier GC with all services that are performed by a resident in a teaching facility under the direction of a teaching physician.

E/M Services for a Given Encounter

  • The selection of the appropriate level of E/M service is determined according to the code definitions in the American Medical Associates' Current Procedural Terminology (AMA/CPT) book and any applicable documentation guidelines.

For the purposes of payment, E/M services billed by teaching physicians require that the medical records must demonstrate:

  1. The teaching physician performed the service

    Or
  2. Was physically present during the critical or key portions of the service when performed by the resident

    And
  3. The participation of the teaching physician in the management of the patient
  4. Documentation by the resident of the presence and participation of the teaching physician is NOT sufficient to establish the presence and participation of the teaching physician.
    1. The presence of the teaching physician during E/M services may be demonstrated by the notes in the medical records made by physicians, residents, or nurses.
  5. For medical review, the combined entries into the medical record by the teaching physician and the resident constitute the documentation for the service and together must support the medical necessity of the service.

The presence of the teaching physician during E/M services may be demonstrated by the notes in the medical records made by physicians, residents, or nurses.

E/M Service Documentation Provided by Student

Any contribution and participation of students to the performance of a billable service (other than the review of systems and/or past family/social history which are not separately billable, but are taken as part of an E/M service):

  • Must be performed in the physical presence of a teaching physician

    Or
  • In the physical presence of a resident in a service meeting the requirements set forth

CR10412 revises the Medicare Claims Processing Manual to allow the teaching physician to verify in the medical record any student documentation of components of E/M services, rather than re-documenting the work. 

GC Modifier

  • Definition: Service has been performed in Part by a Resident under the Direction of a Teaching Physician
  • Submit this modifier with all services that are performed by a resident in a teaching facility under the direction of a teaching physician.
    • This modifier is for informational use only and may be submitted with all procedure codes.
    • If other modifiers also apply, submit the other modifiers first, followed by HCPCS modifier GC.

Additional Information

For procedures that take only a few minutes (five minutes or less) to complete (i.e. simple suture) and involve relatively little decision making once the need for the operation is determined, the teaching surgeon must be present for the entire procedure in order to bill for the procedure.

The patient medical record must document the extent of the teaching physician's participation in the review and direction of the services furnished to each beneficiary. The extent of the teaching physician's participation may be demonstrated by the notes in the medical records made by physicians, residents, or nurses.

Reference:

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