Overarching Criterion     CMS has implemented the overarching criterion for E/M services which makes it clear that medical necessity is the driving force of the level of service assignment. Specifically, CMS states in their statement of overarching criterion, "It would not be medically necessary or appropriate to bill a higher level of evaluation and management service when a lower level of service is warranted. The volume of documentation should not be the primary influence upon which a specific level of service is billed." (Medicare Claims Processing Manual 30.6.1) The overarching criteria is subjective, brief and to the point but provides no mechanism to operationalize the guidance. It relies solely on physician’s judgment to document what level of exam or history is required for any condition. The overarching criterion is…