FAQ: CMS Student Documentation

On November 1, 2019, the Centers for Medicare and Medicaid Services (CMS) issued a new final rule amending the agency’s previous restrictions on the use of student medical record documentation during the provision of evaluation and management (E/M) services for billing purposes. Effective January 1, 2020, all preceptors of PA students, including PAs, physicians, and nurse practitioners will be allowed to verify, rather than reperform, documentation provided by students. To learn more about this new policy, please see the list of frequently asked questions below:


What regulatory changes did CMS finalize in the 2020 Physician Fee Schedule final rule?

In the final rule, CMS removed restrictions on the use of student-provided documentation of evaluation and management services for billing purposes. As a result of the 2020 Physician Fee Schedule final rule, physician, PA, and APRN preceptors will be allowed to verify documentation provided by PA, medical, and APRN students.

When do these new regulations go into effect?

January 1, 2020.

Can preceptors verify the documentation provided by students outside of their professional discipline (e.g. could a PA verify the documentation provided by a medical student?)

Yes, there are no restrictions imposed by CMS on the verification of student documentation on the basis of profession.

Did CMS address clinician physical presence requirements in the final rule?

No. Because a change to current physical presence requirements was not addressed in the proposed rule, the agency opted not to consider changes in the final rule.

Were any significant changes made between the proposed and final Physician Fee Schedule proposed rules?

Yes. In the 2020 Physician Fee Schedule proposed rule, CMS proposed to expand the use of student documentation generally without explicitly stating the types of students. Because of our belief that the new rule should be unambiguous, we argued for an improvement to the proposed rule. CMS found this argument persuasive and edited the final rule to explicitly include PA and APRN students to eliminate the potential for future confusion among clinicians, practices, systems and compliance officers regarding the agency’s intentions.

What if an administrator or compliance officer is still confused and remains unwilling to follow CMS’ rules on documentation?

Please refer them to §§ 410.20, 410.69, 410.74, 410.75, 410.76, and 410.77, which can be found in the final rule.

Does PAEA have suggestions regarding how to communicate with preceptors and practice administrators regarding these documentation changes?

Yes, please see PAEA’s suggested messaging here.

For more information or with additional questions, please contact Director of Government Relations Tyler Smith at tsmith@PAEAonline.org.