Teaching Physician Attestations – Primary Care Exception

The primary care setting is the one area the teaching physician gets a pass on the personal presence requirement when using residents in the care of their patients. Up to a point. If the visit goes beyond a level three, the teaching physician must demonstrate personal presence and participation.

Additionally, Medicare has approved wellness visits to be performed in the Primary Care Exception setting. The services listed below may be performed independently by the resident. The attending should discuss the case immediately following the visit, or as soon as possible.

CPT Codes

The teaching attestation statement should demonstrate that the case was discussed with the resident, and they either agree with their findings, or, they may agree with the exception of, whatever.

Example:  I discussed Javier’s care with Dr. Jones. I have reviewed her note and agree with her findings and treatment plan.

There are other criteria that must be met by the supervising attending. In an effort to keep the article short, you can read those requirements on pages 11-12of transmittal 811,  and pages 9-10 of transmittal 2303.

Residency programs most likely to qualify for the primary care exception include:

  • Family Practice,
  • IM/General Medicine
  • IM/Geriatric medicine
  • Pediatrics
  • Obstetrics and/or Gynecology

If you have questions regarding Teaching Physician requirements, please reach out to your compliance liaison. You may also reach out to Jay.McVean@uth.tmc or Caroline.Wolbrecht@uth.tmc.edu.

CMS/Novitas Resources:

Teaching Physician Fact Sheet

Teaching Physician Guidelines

Transmittal 11842 2023 E/M Changes

Transmittal 2303 Teaching Physicians

Transmittal 811 Teaching Physicians

Transmittal 4283 Teaching Physicians