Know Payer Rules Before Using Scribes in the ED

Mon, Feb 2, 2015 --

Skill Sharpener

Check your policies and guidelines for these 4 must haves.

Emergency departments (EDs) across the country witnessed multiple changes in the recent past owing to the health care reform. In particular, EDs have increased the use of electronic health records (EHRs) and the use of scribes. A scribe assists doctors by expediting the documentation of the history and physical examination into the medical record for each patient. The implementation of EHRs made the documentation process more extensive as well as time consuming, thus necessitating the work of scribes. However, many payers have specific policies and guidelines about how scribes should work.

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Before you decide to utilize scribes in the ED, it is wise to know some of the payer rules:

  1. A scribe must document the name and designation of himself as well as the doctor.
  2. A scribe must document everything the doctor says, word for word.
  3. The scribe must use his own user name to access the system while updating the EHR.
  4. The doctor must attest and sign the EHR after he has reviewed the accuracy of the document.

What Qualifications Should a Scribe Possess?

A scribe works as a human tape recorder; therefore, it helps if she has sound understanding of medical terminology, typical ED situations, procedures clinicians perform  in the ED, and commonly used drugs. However, scribes do not need  specific training or qualifications. Medicare allows a scribe who is an ancillary staff member to document review of systems (ROS) and past medical, family, and social history (PFSH). Other than that, scribes should document only information the physician  dictated.

Home In on CMS Guidelines About Scribes

The Centers for Medicare & Medicaid Services (CMS) allow doctors to use a scribe for documentation in an ED. However, it is not appropriate for doctors to merely sign the resulting note. Because the doctor is solely responsible for the medical records, she should sign the note only after she has confirmed the accuracy of the documentation. Similarly, The Joint Commission (TJC) surveyors also encourage physicians to authenticate the work done by a scribe.

Another Licensed Practitioner Sharing the Service With the Physician?

In a case where a non-physician practitioner (NPP) independently evaluates the patient and the supervising physician later reviews and/or co-signs the EHR, payers will consider the visit to be a shared service and not a “scribe” situation. You should bill the service under the supervising physician’s National Provider Identifier (NPI). However, the documentation should include two separate face-to-face encounters for the patient, including one with the NPP as well as one with the supervising physician. This is a requirement for a shared visit in which each provider performs a portion of the E/M.


Deborah concentrates on coding and compliance for radiology and cardiology, including the tricky world of interventional procedures, as well as oncology and hematology. Since joining The Coding Institute in 2004, she’s also covered the ins and outs of coding for orthopedics, audiology, skilled nursing facilities (SNFs), and more.

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