- CMS will permanently allow teaching physicians to bill for their services involving residents through virtual presence only for services furnished in residency training sites in rural areas to meet the requirement that they be present for the key portion of the service. CMS allows teaching physicians involving residents in providing care at primary care centers to provide the necessary direction, management and review for the resident’s services using interactive, real-time audio/video communications technology. For these sites, residents furnishing services at primary care centers may furnish an expanded set of services to beneficiaries, including communication technology-based services and inter-professional consults.
- CMS amended the resident moonlighting policy to permanently expand the settings in which the services of residents that are not related to their approved GME programs and are performed in the outpatient department, emergency department, or inpatient setting of a hospital in which they have their training program are separately billable physician’s services for which payment may be made.
- During a TH visit, the medical record must clearly reflect how the teaching physician was present to the resident during the key portion of the E&M service. For example, the medical record could document the physical or virtual presence of the teaching physician during the key portion of the service.
- Payment may be made for the interpretation of diagnostic radiology and other diagnostic tests if the interpretation is performed by a resident when the teaching physician is present through audio/video real-time communications technology. A physician other than the resident must still review the resident’s interpretation.
- If the teaching physician is virtually present and bills for services during which there is a disruption to the virtual connection between the teaching physician and the resident who is with the patient, the encounter should be paused until the connection resumes, or the appointment should be rescheduled.