Using PAs and NPs as Scribes

May 25, 2017

Our group is really having a difficult time getting all of the medical record information into the computer. Is it okay to use our PAs and NPs as scribes when they have some down time?

We certainly understand your frustration with inputting data in to the EMR. The question you ask is rather complex and will take a bit of homework for your group to determine if this is the best use of an allied health professional. A scribe in the medical office is just like a court reporter.  They may only document exactly what is stated by the physician or NPP during the encounter and just like a court reporter; they don’t get to ask any questions. You may not combine the work of a PA/NP when they are acting as a scribe with that of a physician and bill it under the MD’s NPI. The practitioner who bills for the services is expected to be the person delivering the services and creating the record, which is simply recorded by another person/the scribe. Finally, the record should be signed by both parties (the scribe and the physicians) attesting to their role in the creation of the record. The practitioner must attest to having independently performed the service and agree with the information as documented by the scribe. A PA/NP who performs part of the encounter for a patient (e.g. history) and then “scribes” the remainder of the encounter is not functioning as a scribe.

For more clarity on the issue, CGS Medicare updated their guidance article recently.  Located here:

In part it states:

Record entries made by a “scribe” should be made upon dictation by the physician, and should document clearly the level of service provided at that encounter. It is inappropriate for the scribe to see the patient separately from the physician and make entries in the record unless the employee is a licensed, certified NPP billing Medicare for services under the NPP name and number.

Medicare pays for medically necessary and reasonable services, and expects the person receiving payment to be the one delivering the services and creating the record. There is no “incident to” billing in the hospital setting (in-patient or out-patient). Thus, the scribe should be merely that, a person who writes what the physician dictates and does. This individual should not act independently, and there is no payment for this activity. The physician is ultimately accountable for the documentation, and should sign and note after the scribe’s entry, that the note accurately reflects the work done by the physician, which is reflected in the affirmation above.

*This response is based on the best information available as of 05/25/17.



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