CMS Guidelines for Scribes

As you may know, Medicare claims submitted to CMS for reimbursement are processed by Medicare Administrative Contractors (or MACs).  MACs are private companies with whom CMS has contracted to administer all Medicare Part A and B claims within certain jurisdictions.  (Medicare Part A covers inpatient hospital services, among others; Medicare Part B covers physician services, outpatient care, and other medically necessary services).

Originally, CMS divided the country into 15 A/B MAC jurisdictions and awarded each jurisdiction through competitive procedures to various private companies.  However, over the next several years, the 15 A/B MAC jurisdictions will be consolidated into 10 larger jurisdictions for cost saving purposes.

Each MAC has the authority to issue its own documentation guidelines for all claims submitted within its jurisdiction, including guidelines on scribe use.  Each of the MACs listed below have issued guidelines, an FAQ, or bulletin with regard to the use of scribes (with links to each):

Generally speaking, the MACs state that scribes may document the words and/or activities as they are performed by the practitioner during a patient encounter (much like the Joint Commission guidelines).  While the practitioner is ultimately responsible for the record, scribes should be trained to have a basic understanding of the E/M Documentation Guidelines as set out by CMS.  Furthermore, several MACs have issued specific signature requirements to be used when scribes are utilized (for example, clearly indicating who performed the service, who recorded the service, the qualifications of each, and the date and signature of both the practitioner and scribe).  When adding scribes to your practice, it is important to consult the MAC guidelines for your jurisdiction in order to develop CMS compliant scribe workflows and policies.

For more information on MAC jurisdictions and to determine which MAC operates within your state, please visit the CMS website on A/B MACs found here.

- Brittany Baine, J.D.

 

Resources:

1. 1995 E/M Documentation Guidelines, Centers for Medicare and Medicaid Services.

2. 1997 E/M Documentation Guidelines, Centers for Medicare and Medicaid Services.

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