CMS Finalizes Student Documentation Proposal

After reviewing more than 42,000 comments, including more than 1,000 submitted by the PA education advocacy community, the Centers for Medicare and Medicaid Services has finalized its proposed changes allowing all preceptors to verify, rather than re-perform, documentation provided by PA students during the provision of E/M services.

In response to comments submitted by PAEA, the agency modified its original proposal to explicitly state that the documentation of PA students could be verified — instead of “students” generally. This clarification is critical in mitigating future potential confusion by practices, systems, and compliance officers regarding the use of student documentation.

The agency stated:

“We acknowledge that uncertainty in the healthcare industry and for [Medicare Administrative Contractors] about the specific types of students who were allowed to make notes in the medical record which teaching physicians could review and verify without re-documenting was a factor we considered in proposing to revise the documentation requirements in the CY 2020 [Physician Fee Schedule] proposed rule. We find the comment to be persuasive regarding the need for us to be more explicit regarding the flexibility we intend to establish for other physicians, PAs, and APRNs and their students. Given that the initial impetus for our proposal was to address potential confusion about our reference in a manual provision to “students,” we would not want to generate any further potential for confusion with this policy. In making our proposal, we referred not only to medical students, but more broadly to students in the disciplines of the clinicians who are authorized to bill the Medicare program for a broad spectrum of health care services, including all level E/M services. We agree with the commenters that it is important to be clear about the scope of this policy and, therefore, we will modify our proposal to explicitly list the types of students for which the medical records documentation policy applies rather than using a generic reference to ‘students.’”

The finalization of this proposal represents the culmination of more than two years of interprofessional advocacy with the Society of Teachers of Family Medicine Preceptor Expansion Initiative — including representatives from the Council on Academic Family Medicine, the Association of American Medical Colleges, AAPA, and PAEA — and using letters of support garnered from Senate Rural Health Caucus Co-Chairs John Barrasso (R-WY) and Tina Smith (D-MN) and four HRSA advisory committees:

  • The Advisory Committee on Training in Primary Care Medicine and Dentistry
  • The Advisory Committee on Interdisciplinary, Community-Based Linkages
  • The National Advisory Council on Nursing Education and Practice
  • The Council on Graduate Medical Education

Complementing this outreach, the perspective offered by PA faculty and students from across the country was invaluable in securing this critical victory.

This policy change will go into effect on January 1, 2020. For additional questions regarding upcoming changes to CMS’ student documentation policy, please contact