In the 1995 and 1997 CMS Guidelines for E/M services, the following comment is stated for Review of Systems:

"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."

Based on the above comment, for a Review of System to be considered a "complete ROS", could a physician document the pertinent positives or pertinent negative review of systems and then mention that all other systems were reviewed and are negative? Or, do they have to list 10 review of systems regardless?