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What is the difference between “Moderate” and “High complexity” medical decision making under the Centers for Medicare and Medicaid Services (CMS) rule?

The level of medical decision making (“Straightforward/Low complexity”, “Moderate complexity”, “High complexity”) or MDM should reflect the intensity of the cognitive labor performed by the clinician.

The MDM level is determined by 3 important factors:

As for the nature of clinical problems, in contrast to stable problems (1 point), the following receive higher points:

As for the amount and complexity of data reviewed by the clinician, the following receive higher points (2 points each)

More routine activities such as simply reviewing or ordering lab, radiology, or other tests, discussing tests results with performing physician, or obtaining old records and/or history from someone other than patient receive only 1 point each.

The 3rd element of MDM scoring system is based on the risk of complications and/or morbidity or mortality determined by the severity of the presenting problem(s), complexity of the diagnostic procedure(s) ordered, and management options selected.

Patients may be considered “High risk” of complications and/or morbidity or mortality when any of following is documented: 

A. Presenting problem(s)

B. Diagnostic procedure(s) ordered

C. Management options selected

Less severe conditions such as pyelonephritis, pneumonitis, colitis, or head injury with brief loss of consciousness, and less complicated procedures such as diagnostic endoscopies and elective major surgery with no identified risk factor are considered “Moderate risk”.

 To qualify for “High complexity” care, at least 2 of the following must be present:

Otherwise, your patient encounter qualifies for “Moderate” or lower complexity  care.

For further details on how to determine the MDM level on your individual patient go to:

https://www.ngsmedicare.com/ngs/wcm/connect/3632a905-b697-4266-8fc0-2aa2a84fedb2/1074_0514_EM_Documentation_Training_Tool_508.pdf?MOD=AJPERES

Contributed by Jodie Medeiros, CPC, COC, ICDCT-CM, Billing Specialist, Mass General Hospital, Boston, MA

 

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