The government is proposing that physician practices furnishing chronic care management services to Medicare beneficiaries use electronic health records certified to at least 2014 Edition meaningful use requirements.
The meaningful use program has been voluntary, although eligible professionals not participating face reduced Medicare reimbursements. The program remains voluntary, but the possibility now looms that an exception may be made for chronic care.
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 being 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.
Given the standards and requirements already in place for health care practitioners and that will apply to those who furnish and bill for CCM services, we have decided not to propose an additional set of standards that must be met in order for practitioners to furnish and bill for CCM services, CMS explains in the proposed rule. 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.
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 patients health status, needs and services, and through frequent communication and exchange of information with the beneficiary and among health care practitioners treating the beneficiary.
As such, 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 if care is to be coordinated effectively, all communication must be timely and it must include the information that each team member needs to know to furnish care that is congruent with a patients needs and preference, CMS says in the proposed rule. In addition, those furnishing CCM services need to establish reliable flows of information from emergency departments, hospitals and providers of post-acute care services to track their CCM patients receiving care in those settings.
That means CMS wants use of EHRs or other health IT or health information exchange platform that includes an electronic care plan assessable to all providers in a practice including those providing care outside normal business hours, and that the care plan can be shared with care team members outside the practice.
We believe this scope of service element will ensure that practitioners have adequate capabilities to fully furnish CCM services, allow practitioners to innovate around the systems that they use to furnish these services, and avoid overburdening small practices, according to the rule. We believe that allowing flexibility as to how providers capture, update and share care plan information is important at this stage given the maturity of current electronic health records standards and other electronic tools in use in the market today for care planning.
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