E & M Coding Is Broken. Here Is My Solution.

Following is a letter I recently submitted to the American Medical Association regarding coding, physician documentation and the opportunity to make some changes to better the process.

July 12, 2018

To whom it may concern:

I am writing to you today with an idea I hope you will take into consideration. I am a long-time medical billing and coding consultant and have worked in multiple physician specialties for over 35 years. In the last six months, I have been engaged with a physician client in two law suits with the DOJ and FBI relative to physician coding issues. As we all know, E&M coding is outdated and too complex. This, in turn, makes the audit process cumbersome and overly expensive to audit notes.

Perhaps with the current transition from Obama Care to President Trump’s proposed health plan, there is an opportunity for change that will make the process more manageable for everyone involved (including the insurance companies).

My Recommendations:

  • Down-grade documentation requirements for “history and exam” and create new criteria for “history of present illness” and “medical decision-making”.

  • Place the focus specifically on “history of present illness” and “medical decision-making”.

  • Allow each specialty to create its own guidelines for medical decision-making (many societies are creating “alternative” meaningful use guidelines; allow these to be the core of medical decision- making notes)

  • Create more levels of care.


  • These recommendations will allow for simplicity and place the 3 most important items at the forefront: diagnosis, chief complaint and lab results.

  • Many physicians are creating redundant notes in order to cover their bases. Therefore, auditors are seeing this as “over-coding”, which is resulting in unnecessary, expensive audits.

  • The current process is cumbersome and confusing. Therefore, physicians are all over the board relative to how they document their patient visits. The above would enable more uniformity.

  • There is a need for more levels of care based on patient condition of morbidity and mortality.

  • This would require less time on the part of the physician and enable them to spend more time with their patients.

I would appreciate a response to this idea and potential steps to move it forward.

Sincerely, Martin E. Neltner

(859) 743-6192

#EMCoding #AMA

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