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Tactic 1: Work With CMS to Revise Student Documentation Guidelines

The rules regarding the use of student notes for billing purposes have hampered medical education and increased the administrative burden on the teaching physician. These guidelines limit the student documentation role to review of systems and/or past family/social history and prohibit teaching physicians from referring to a student’s documentation of other parts of the history, physical exam findings, or decision-making. This team’s task is to explore with CMS, and other federal bodies as needed, ways to revise the student documentation guidelines to help relieve unnecessary administrative burdens on preceptors and increase the active learning of students.  


The Tactic 1 team and others invested in the outcome created a one-page request that was vetted by several organizations. Members of the team then met with CMS in December 2017, providing arguments in favor of the change and proposing revised transmittal language. CMS requested data to quantify the amount of time this change would save in a preceptor's clinical visit. The tactic team created a survey (PDF), which received 1,900 responses in 11 days, and sent the data to CMS on January 24, 2018. 

On February 2, CMS released a revised transmittal, Pub 100-04 Medicare Claims Processing Manual (updated May 31), that “allows the teaching physician to verify in the medical record any student documentation of components of E/M services, rather than redocumenting the work." The new transmittal generated numerous compliance questions. In an effort to better clarify how the new guidelines should be operationalized, several organizations involved in the Preceptor Expansion Initiative drafted and submitted–on March 21–a request to confirm the Initiative’s understanding of the new guidelines

On May 8, CMS responded to the request. Answers are incorporated into the FAQs, below.

Resources for Implementation of New Guidelines

Copyright 2018 by Society of Teachers of Family Medicine