CMS Pushing Mandated Certified EHRs For Chronic Care
By Christine Kern, contributing writer
A proposed rule would mandate certified EHRs for care of chronically ill under Medicare Part B.
CMS has followed through with its stated intention of requiring electronic health records for payment of chronic care management (CCM), proposing in its 2015 physician payment rule that physicians receive a separate payment for CCM services, but only if they are using at least the 2014 edition of certified EHR technology.
The possible mandate of certified EHRs to care for the chronically ill is in a proposed rule setting the Part B physician fee schedule for calendar year 2015. The rule from the Centers for Medicare and Medicaid Services is available here and was published July 11 in the Federal Register.
In the final Part B rule for calendar year 2014, CMS noted it planned to develop standards for physician practices that provide CCM services to ensure that those billing for such services can fully furnish them, and intended to propose the standards for CY 2015. Now the agency is backing away but adding the EHR caveat.
“Instead of proposing a new set of standards applicable only to CCM services, we have decided to emphasize that certain requirements are inherent in the elements of the existing scope of service for CCM services, and clarify that these must be met in order to bill for CCM services,” CMS explains in the proposed rule.
“In one area – that of electronic health records – we are concerned that the existing elements of the CCM service could leave some gaps in assuring that beneficiaries consistently receive care management services that offer the benefits of advanced primary care as it was envisioned when this service was created,” the rule continues. “It is clear that effective care management can be accomplished only through regular monitoring of the patient’s health status, needs and services, and through frequent communication and exchange of information with the beneficiary and among health care practitioners treating the beneficiary.”
CMS wants to ensure that CCM providers have an EHR that supports a problem list, medications and medication allergy checks, care coordination and electronic exchange of a summary of care record to better manage care transitions.
"We believe that requiring those that furnish CCM services to maintain and share an electronic care plan will alleviate the development of duplicative care plans or updates and the associated errors that can occur when care plans are not systematically reconciled,” CMS wrote in the rule.
Other requirements needed to bill for CCM services include 24/7 access to care, creation of a patient centered plan document and additional specific billing obligations. The 2014 physician payment rule did not require physicians to adopt EHRs, but did specify that CCM and care coordination includes inputting the full list of problems, medications and allergies in the EHR – and had suggested that standards for future CCM should include required use of EHRs that meet Meaningful Use.
The proposed rule also relaxes several requirements of the Meaningful Use incentive program itself. CMS would no longer require that eligible professionals ensure their certified EHR product has been recertified, allow reporting flexibility where certain errors in a clinical quality measure have been discovered, and reduce the reporting obligations on comprehensive primary care initiative practice sites.
Comments on the proposed 2015 fee schedule are due Sept. 2.