1995 Documentation Guidelines for Patient Evaluation and Management (E&M) Services

1995 DOCUMENTATION GUIDELINES
FOR EVALUATION & MANAGEMENT SERVICES

I. INTRODUCTION

WHAT IS DOCUMENTATION AND WHY IS IT IMPORTANT?

Medical record documentation is required to record pertinent facts, findings, and observations
about an individual's health history including past and present illnesses, examinations, tests,
treatments, and outcomes. The medical record chronologically documents the care of the patient
and is an important element contributing to high quality care. The medical record facilitates:
• the ability of the physician and other health care professionals to evaluate and plan the
patient's immediate treatment, and to monitor his/her health care over time.
• communication and continuity of care among physicians and other health care
professionals involved in the patient's care;
• accurate and timely claims review and payment;
• appropriate utilization review and quality of care evaluations; and
• collection of data that may be useful for research and education.
An appropriately documented medical record can reduce many of the "hassles" associated with
claims processing and may serve as a legal document to verify the care provided, if necessary.
WHAT DO PAYERS WANT AND WHY?
Because payers have a contractual obligation to enrollees, they may require reasonable
documentation that services are consistent with the insurance coverage provided. They may
request information to validate:
• the site of service;
• the medical necessity and appropriateness of the diagnostic and/or therapeutic services
provided; and/or
• that services provided have been accurately reported.

II. GENERAL PRINCIPLES OF MEDICAL RECORD DOCUMENTATION

The principles of documentation listed below are applicable to all types of medical and surgical
services in all settings. For Evaluation and Management (E/M) services, the nature and amount
of physician work and documentation varies by type of service, place of service and the patient's
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status. The general principles listed below may be modified to account for these variable
circumstances in providing E/M services.
1. The medical record should be complete and legible.
2. The documentation of each patient encounter should include:
• reason for the encounter and relevant history, physical examination findings and
prior diagnostic test results;
• assessment, clinical impression or diagnosis;
• plan for care; and
• date and legible identity of the observer.
3. If not documented, the rationale for ordering diagnostic and other ancillary services
should be easily inferred.
4. Past and present diagnoses should be accessible to the treating and/or consulting
physician.
5. Appropriate health risk factors should be identified.
6. The patient's progress, response to and changes in treatment, and revision of diagnosis
should be documented.
7. The CPT and ICD-9-CM codes reported on the health insurance claim form or billing
statement should be supported by the documentation in the medical record.

III. DOCUMENTATION OF E/M SERVICES

This publication provides definitions and documentation guidelines for the three key components
of E/M services and for visits which consist predominately of counseling or coordination of care.
The three key components--history, examination, and medical decision making--appear in the
descriptors for office and other outpatient services, hospital observation services, hospital
inpatient services, consultations, emergency department services, nursing facility services,
domiciliary care services, and home services. While some of the text of CPT has been repeated
in this publication, the reader should refer to CPT for the complete descriptors for E/M services
and instructions for selecting a level of service. Documentation guidelines are identified by
the symbol •DG.
The descriptors for the levels of E/M services recognize seven components which are used in
defining the levels of E/M services. These components are:
• history;
• examination;
• medical decision making;
• counseling;
• coordination of care;
• nature of presenting problem; and
• time.
The first three of these components (i.e., history, examination and medical decision making) are
the key components in selecting the level of E/M services. An exception to this rule is the case
of visits which consist predominantly of counseling or coordination of care; for these services
time is the key or controlling factor to qualify for a particular level of E/M service.
For certain groups of patients, the recorded information may vary slightly from that described
here. Specifically, the medical records of infants, children, adolescents and pregnant women may
have additional or modified information recorded in each history and examination area.
As an example, newborn records may include under history of the present illness (HPI) the
details of mother's pregnancy and the infant's status at birth; social history will focus on family
structure; family history will focus on congenital anomalies and hereditary disorders in the
family. In addition, information on growth and development and/or nutrition will be recorded.
Although not specifically defined in these documentation guidelines, these patient group
variations on history and examination are appropriate.

A. DOCUMENTATION OF HISTORY

The levels of E/M services are based on four types of history (Problem Focused, Expanded
Problem Focused, Detailed, and Comprehensive.) Each type of history includes some or all of
the following elements:
• Chief complaint (CC);
• History of present illness (HPI);
• Review of systems (ROS); and
• Past, family and/or social history (PFSH).
The extent of history of present illness, review of systems and past, family and/or social history
that is obtained and documented is dependent upon clinical judgement and the nature of the
presenting problem(s).
The chart below shows the progression of the elements required for each type of history. To
qualify for a given type of history, all three elements in the table must be met. (A chief
complaint is indicated at all levels.)

History of Present Illness (HPI)	Review of Systems (ROS)	Past, Family, and/or Social History (PFSH)	Type of History
Brief	N/A	N/A	Problem Focused
Brief Problem	Pertinent	N/A	Expanded Problem Focused
Extended	Extended	Pertinent	Detailed
Extended	Complete	Complete	Comprehensive

DG: The CC, ROS and PFSH may be listed as separate elements of history, or they
may be included in the description of the history of the present illness.
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DG: A ROS and/or a PFSH obtained during an earlier encounter does not need to
be re-recorded if there is evidence that the physician reviewed and updated
the previous information. This may occur when a physician updates his or
her own record or in an institutional setting or group practice where many
physicians use a common record. The review and update may be documented
by:
- describing any new ROS and/or PFSH information or noting there
  has been no change in the information; and
- noting the date and location of the earlier ROS and/or PFSH.
DG: The ROS and/or PFSH may be recorded by ancillary staff or on a form
completed by the patient. To document that the physician reviewed the
information, there must be a notation supplementing or confirming the
information recorded by others.
DG: If the physician is unable to obtain a history from the patient or other source,
the record should describe the patient's condition or other circumstance
which precludes obtaining a history.

Definitions and specific documentation guidelines for each of the elements of history are listed
below.

CHIEF COMPLAINT (CC)
The CC is a concise statement describing the symptom, problem, condition, diagnosis, physician
recommended return, or other factor that is the reason for the encounter.
•DG: The medical record should clearly reflect the chief complaint.
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HISTORY OF PRESENT ILLNESS (HPI)
The HPI is a chronological description of the development of the patient's present illness from
the first sign and/or symptom or from the previous encounter to the present. It includes the
following elements:

location,
quality,
severity,
duration,
timing,
context,
modifying factors, and
associated signs and symptoms.

Brief and extended HPIs are distinguished by the amount of detail needed to accurately
characterize the clinical problem(s).

A brief HPI consists of one to three elements of the HPI.

DG: The medical record should describe one to three elements of the present
illness (HPI).

An extended HPI consists of four or more elements of the HPI.

DG: The medical record should describe four or more elements of the present
illness (HPI) or associated comorbidities.

REVIEW OF SYSTEMS (ROS)

A ROS is an inventory of body systems obtained through a series of questions seeking to identify
signs and/or symptoms which the patient may be experiencing or has experienced.
For purposes of ROS, the following systems are recognized:

Constitutional symptoms (e.g., fever, weight loss)
Eyes
Ears, Nose, Mouth, Throat
Cardiovascular
Respiratory
Gastrointestinal
Genitourinary
Musculoskeletal
Integumentary (skin and/or breast)
Neurological
Psychiatric
Endocrine
Hematologic/Lymphatic
Allergic/Immunologic

A problem pertinent ROS inquires about the system directly related to the problem(s) identified
in the HPI.

DG: The patient's positive responses and pertinent negatives for the system
related to the problem should be documented.

An extended ROS inquires about the system directly related to the problem(s) identified in the
HPI and a limited number of additional systems.

DG: The patient's positive responses and pertinent negatives for two to nine
systems should be documented.

A complete ROS inquires about the system(s) directly related to the problem(s) identified in the
HPI plus all additional body systems.

DG: At least ten organ systems must be reviewed. Those systems with positive or
pertinent negative responses must be individually documented. For the
remaining systems, a notation indicating all other systems are negative is
permissible. In the absence of such a notation, at least ten systems must be
individually documented.

PAST, FAMILY AND/OR SOCIAL HISTORY (PFSH)

The PFSH consists of a review of three areas:
• past history (the patient's past experiences with illnesses, operations, injuries and
treatments);
• family history (a review of medical events in the patient's family, including diseases
which may be hereditary or place the patient at risk); and
• social history (an age appropriate review of past and current activities).
For the categories of subsequent hospital care, follow-up inpatient consultations and subsequent
nursing facility care, CPT requires only an "interval" history. It is not necessary to record
information about the PFSH.
A pertinent PFSH is a review of the history area(s) directly related to the problem(s)
identified in the HPI.

DG: At least one specific item from any of the three history areas must be
documented for a pertinent PFSH .
A complete PFSH is of a review of two or all three of the PFSH history areas, depending on the
category of the E/M service. A review of all three history areas is required for services that by
their nature include a comprehensive assessment or reassessment of the patient. A review of two
of the three history areas is sufficient for other services.
DG At least one specific item from two of the three history areas must be
documented for a complete PFSH for the following categories of E/M
services: office or other outpatient services, established patient; emergency
department; subsequent nursing facility care; domiciliary care, established
patient; and home care, established patient.
DG: At least one specific item from each of the three history areas must be
documented for a complete PFSH for the following categories of E/M
services: office or other outpatient services, new patient; hospital
observation services; hospital inpatient services, initial care; consultations;
comprehensive nursing facility assessments; domiciliary care, new patient;
and home care, new patient.

B. DOCUMENTATION OF EXAMINATION

The levels of E/M services are based on four types of examination that are defined as follows:

• Problem Focused -- a limited examination of the affected body area or organ system.

• Expanded Problem Focused -- a limited examination of the affected body area or organ
system and other symptomatic or related organ system(s).

• Detailed -- an extended examination of the affected body area(s) and other symptomatic
or related organ system(s).

• Comprehensive -- a general multi-system examination or complete examination of a
single organ system.

For purposes of examination, the following body areas are recognized:

Head, including the face
Neck
Chest, including breasts and axillae
Abdomen
Genitalia, groin, buttocks
Back, including spine
Each extremity

For purposes of examination, the following organ systems are recognized:

Constitutional (e.g., vital signs, general appearance)
Eyes
Ears, nose, mouth and throat
Cardiovascular
Respiratory
Gastrointestinal
Genitourinary
Musculoskeletal
Skin
Neurologic
Psychiatric
Hematologic/lymphatic/immunologic

The extent of examinations performed and documented is dependent upon clinical judgement and
the nature of the presenting problem(s). They range from limited examinations of single body
areas to general multi-system or complete single organ system examinations.

DG: Specific abnormal and relevant negative findings of the examination of the
affected or symptomatic body area(s) or organ system(s) should be
documented. A notation of "abnormal" without elaboration is insufficient.
DG: Abnormal or unexpected findings of the examination of the unaffected or
asymptomatic body area(s) or organ system(s) should be described.
DG: A brief statement or notation indicating "negative" or "normal" is sufficient
to document normal findings related to unaffected area(s) or asymptomatic
organ system(s).
DG: The medical record for a general multi-system examination should include
findings about 8 or more of the 12 organ systems.

C. DOCUMENTATION OF THE COMPLEXITY OF MEDICAL DECISION
MAKING

The levels of E/M services recognize four types of medical decision making (straight-forward,
low complexity, moderate complexity and high complexity). Medical decision making refers to
the complexity of establishing a diagnosis and/or selecting a management option as measured by:
• the number of possible diagnoses and/or the number of management options that must
be considered;
• the amount and/or complexity of medical records, diagnostic tests, and/or other
information that must be obtained, reviewed and analyzed; and
• the risk of significant complications, morbidity and/or mortality, as well as
comorbidities, associated with the patient's presenting problem(s), the diagnostic
procedure(s) and/or the possible management options.

The chart below shows the progression of the elements required for each level of medical
decision making. To qualify for a given type of decision making, two of the three elements in
the table must be either met or exceeded.

Number of diagnoses or management options	Amount and/or complexity of data to be reviewed	Risk of complications and/or morbidity or mortality	Type of decision making
Minimal	Minimal or None	Minimal	*Straightforward*
Limited	Limited	Low	*Low*
Multiple	Moderate	Moderate	*Moderate Complexity*
Extensive	Extensive	High	*High Complexity*

Each of the elements of medical decision making is described below.

NUMBER OF DIAGNOSES OR MANAGEMENT OPTIONS

The number of possible diagnoses and/or the number of management options that must be
considered is based on the number and types of problems addressed during the encounter, the
complexity of establishing a diagnosis and the management decisions that are made by the
physician.
Generally, decision making with respect to a diagnosed problem is easier than that for an
identified but undiagnosed problem. The number and type of diagnostic tests employed may be
an indicator of the number of possible diagnoses. Problems which are improving or resolving
are less complex than those which are worsening or failing to change as expected. The need to
seek advice from others is another indicator of complexity of diagnostic or management
problems.
!DG: For each encounter, an assessment, clinical impression, or diagnosis should
be documented. It may be explicitly stated or implied in documented decisions
regarding management plans and/or further evaluation.
• For a presenting problem with an established diagnosis the record
should reflect whether the problem is: a) improved, well controlled,
resolving or resolved; or, b) inadequately controlled, worsening, or
failing to change as expected.
• For a presenting problem without an established diagnosis, the
assessment or clinical impression may be stated in the form of a
differential diagnoses or as "possible", "probable", or "rule out"
(R/O) diagnoses.
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!DG: The initiation of, or changes in, treatment should be documented. Treatment
includes a wide range of management options including patient instructions,
nursing instructions, therapies, and medications.
!DG: If referrals are made, consultations requested or advice sought, the record
should indicate to whom or where the referral or consultation is made or
from whom the advice is requested.

AMOUNT AND/OR COMPLEXITY OF DATA TO BE REVIEWED

The amount and complexity of data to be reviewed is based on the types of diagnostic testing
ordered or reviewed. A decision to obtain and review old medical records and/or obtain history
from sources other than the patient increases the amount and complexity of data to be reviewed.
Discussion of contradictory or unexpected test results with the physician who performed or
interpreted the test is an indication of the complexity of data being reviewed. On occasion the
physician who ordered a test may personally review the image, tracing or specimen to
supplement information from the physician who prepared the test report or interpretation; this is
another indication of the complexity of data being reviewed.
!DG: If a diagnostic service (test or procedure) is ordered, planned, scheduled, or
performed at the time of the E/M encounter, the type of service, eg, lab or xray,
should be documented.
!DG: The review of lab, radiology and/or other diagnostic tests should be
documented. An entry in a progress note such as "WBC elevated" or "chest
x-ray unremarkable" is acceptable. Alternatively, the review may be
documented by initialing and dating the report containing the test results.
!DG: A decision to obtain old records or decision to obtain additional history from
the family, caretaker or other source to supplement that obtained from the
patient should be documented.
!DG: Relevant finding from the review of old records, and/or the receipt of
additional history from the family, caretaker or other source should be
documented. If there is no relevant information beyond that already obtained,
that fact should be documented. A notation of "Old records reviewed" or
"additional history obtained from family" without elaboration is insufficient.
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!DG: The results of discussion of laboratory, radiology or other diagnostic tests
with the physician who performed or interpreted the study should be
documented.
!DG: The direct visualization and independent interpretation of an image, tracing
or specimen previously or subsequently interpreted by another physician
should be documented.

RISK OF SIGNIFICANT COMPLICATIONS, MORBIDITY, AND/OR MORTALITY

The risk of significant complications, morbidity, and/or mortality is based on the risks associated
with the presenting problem(s), the diagnostic procedure(s), and the possible management
options.
!DG: Comorbidities/underlying diseases or other factors that increase the
complexity of medical decision making by increasing the risk of
complications, morbidity, and/or mortality should be documented.
!DG: If a surgical or invasive diagnostic procedure is ordered, planned or
scheduled at the time of the E/M encounter, the type of procedure, eg,
laparoscopy, should be documented.
!DG: If a surgical or invasive diagnostic procedure is performed at the time of the
E/M encounter, the specific procedure should be documented.
!DG: The referral for or decision to perform a surgical or invasive diagnostic
procedure on an urgent basis should be documented or implied.
The following table may be used to help determine whether the risk of significant complications,
morbidity, and/or mortality is minimal, low, moderate, or high. Because the determination of
risk is complex and not readily quantifiable, the table includes common clinical examples rather
than absolute measures of risk. The assessment of risk of the presenting problem(s) is based on
the risk related to the disease process anticipated between the present encounter and the next one.
The assessment of risk of selecting diagnostic procedures and management options is based on
the risk during and immediately following any procedures or treatment. The highest level of risk
in any one category (presenting problem(s), diagnostic procedure(s), or management options)
determines the overall risk.

TABLE OF RISK
Level of Risk	Presenting Problem(s)	Diagnostic Procedure(s) Ordered	Management Options Selected
Minimal	• One self-limited or minor problem, eg cold, insect bite, tinea corporis	• Laboratory tests requiring venipuncture • Chest x-rays • EKG/EEG • Urinalysis • Ultrasound, eg, echocardiography • KOH prep	• Rest • Gargles • Elastic bandages • Superficial dressings
Low	• Two or more self-limited or minor problems • One stable chronic illness, eg well controlled hypertension or non-insulin dependent diabetes, cataract, BPH • Acute uncomplicated illness or injury, eg, cystitis, allergic rhinitis, simple sprain	• Physiologic tests not under stress, eg, pulmonary function tests • Non-cardiovascular imaging studies with contrast, eg, barium enema • Superficial needle biopsies • Clinical laboratory tests requiring arterial puncture • Skin biopsies	• Over-the-counter drugs • Minor surgery with no identified risk factors • Physical therapy • Occupational therapy • IV fluids without additives
Moderate	• One or more chronic illnesses with mild exacerbation, progression, or side effects of treatment • Two or more stable chronic illnesses • Undiagnosed new problem with uncertain prognosis, eg, lump in breast • Acute illness with systemic symptoms, eg, pyclonephritis, pneumonitis, colitis • Acute complicated injury, eg head injury with brief loss of consciousness	• Physiologic tests under stress, eg, cardiac stress test, fetal contraction stress test • Diagnostic endoscopies with no identified risk factors • Deep needle or incisional biopsy • Cardiovascular imaging studies with contrast and no identified risk factors, eg arteriogram, cardiac catheterization • Obtain fluid from body cavity, eg lumbar puncture, thoracentesis, culdocentesis	• Minor surgery with identified risk factors • Elective major surgery (open, percutaneous or endoscopic) with no identified risk factors • Prescription drug management • Therapeutic nuclear medicine • IV fluids with additives • Closed treatment of fracture or dislocation without manipulation
*High*	• One or more chronic illnesses with severe exacerbation, progression, or side effects of treatment • Acute or chronic illnesses or injuries that pose a threat to life or bodily function, eg multiple trauma, acute MI, pulmonary embolus, severe respiratory distress, progressive severe rheumatoid arthritis, psychiatric illness with potential threat to self or others, peritonitis, acute renal failure • An abrupt change in neurologic status, eg seizure, TIA, weakness, or sensory loss	• Cardiovascular imaging studies with contrast with identified risk factors • Cardiac electrophysiological tests • Diagnostic Endoscopies with identified risk factors • Discography	• Elective major surgery (open, percutaneous or endoscopic) with identified risk factors • Emergency major surgery (open, percutaneous or endoscopic) • Parenteral controlled substances • Drug therapy requiring intensive monitoring for toxicity • Decision not to resuscitate or to de-escalate care because of poor prognosis

D. DOCUMENTATION OF AN ENCOUNTER DOMINATED BY COUNSELING OR
COORDINATION OF CARE

In the case where counseling and/or coordination of care dominates (more than 50%) of the
physician/patient and/or family encounter (face-to-face time in the office or other outpatient setting or
floor/unit time in the hospital or nursing facility), time is considered the key or controlling factor to
qualify for a particular level of E/M services.
!DG: If the physician elects to report the level of service based on counseling
and/or coordination of care, the total length of time of the encounter (face-to-face or
floor time, as appropriate) should be documented and the record should describe
the counseling and/or activities to coordinate care.