CMS Billing Guidelines and Student Documentation: a New Era or New Burden?

  • Andre KumarEmail author
  • Jeffrey Chi


The Centers for Medicare and Medicaid Services (CMS) recently revised their Medicare Claims Processing Manual with the addition of CR 10412, a provision that permits teaching providers to fully bill for medical student notes. This change will have significant implications on the documentation duties of teaching physicians and trainees. Potential benefits of this provision include reduced documentation burden on house officers, improved medical student empowerment, and the infusion of more original content into the electronic medical record. However, these benefits may be offset by shifting the burden of documentation onto medical students, which may compromise their time spent with patients and overall wellness. In this perspective, we review the changes that occurred with CR 10412 and their potential impact on documentation across the medical education spectrum.


medical education direct patient care resident training electronic medical record 


Compliance with Ethical Standards

Conflict of Interest

The authors declare that they do not have a conflict of interest.


  1. 1.
  2. 2.
    Ouyang D, Chen JH, Hom J et al. Internal Medicine Resident Computer Usage: An Electronic Audit of an Inpatient Service. JAMA Intern Med. 2016;176(2):252–254.CrossRefGoogle Scholar
  3. 3.
    Block L, Habicht R, Wu AW et al. In the Wake of the 2003 and 2011 Duty Hours Regulations, How Do Internal Medicine Interns Spend Their Time? J Gen Intern Med. 2013; 28(8):1042–1047.CrossRefGoogle Scholar
  4. 4.
    Desai SV, Asch DA, Bellini LM et al. Educational outcomes in a duty-hour flexibility trail in internal medicine. N Engl J Med. 2018;378(16):1594–1950.CrossRefGoogle Scholar
  5. 5.
    Rosenthal DI and Verghese A. Meaning and the Nature of Physicians' Work. N Engl J Med. 2016;375(19):1813–1815.CrossRefGoogle Scholar
  6. 6.
    Shanafelt TD, Dyrbye LN, West CP. Addressing Physician Burnout: The Way Forward. JAMA. 2017;317(9):901–902.CrossRefGoogle Scholar
  7. 7.
    Wang MD, Khanna R, Najafi N. Characterizing the Source of Text in Electronic Health Record Progress Notes. JAMA Intern Med. 2017;177(8):1212–1213.CrossRefGoogle Scholar

Copyright information

© Society of General Internal Medicine 2019

Authors and Affiliations

  1. 1.Department of MedicineStanford University School of MedicineStanfordUSA

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