Woa -- do you have a link to the regulation (chapter, but looking at Medicare fully now) to things that are designed to "systematically to enhance bill-ability"?
So you're saying if you use a templating tool to be more efficient and save time, it's explicitly not allowed AND you're opening up either yourself or the technology tool to malpractice litigation?!
Malpractice is a totally separate thing from Medicare Fraud. With respect to malpractice, having automated or semi-automated encounter notes with huge systematic similarity looks absolutely terrible if something goes wrong. Don't take my word for it, consult your attorneys.
With respect to Medicare fraud see the False Claims act and its interpretation in the enforcement actions against many parties beginning in 2016. Keywords would be like "not medically necessary" and "upcoding". I believe the monster enforcement action just this week against GHC also involves that.
Let us not forget “stand in your shoes” Stark provisions which made many a brother-in-law who owned a DME company very sad.
Hospices dropping off cookies with their contact information is kosher. Incentivizing a medical office to hit 100 nebulizer-orders, or cpap referrals -> federal prison.
So you're saying if you use a templating tool to be more efficient and save time, it's explicitly not allowed AND you're opening up either yourself or the technology tool to malpractice litigation?!
Goodness!