2019 Documentation Changes

Can anyone provide any guidance on how your company will be handling 2019 Medicare Physician Fee Schedule change regarding practitioners not needing to re-record the defined list of required elements if there is evidence that the practitioner reviewed the previous information and update it as needed?

Does this include both history and exam elements? Also, if the practitioner does state that they have reviewed prior data, and nothing has changed since the last visit, would you count those history and exam elements from the previous visit that have not changed for the current date of service?

When CMS states "what has changed since the last visit" what are you considering the last visit to be? Would the last visit be the immediate previous visit that took place or would the last visit apply to visits from 2 or 3 visits ago? I am worried that this new guideline will cause the providers to feel like they can put this on every single note causing a domino effect that would make one have to go back multiple visits to find the note they are actually referring to.

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