A final rule on Medicare physician payments in 2015 emphasizes improved chronic care management (CCM) and the supporting role of electronic health records, and loosens certification criteria a little more.

Medicare will pay a separate fee to account for the “relative resources” used in furnishing CCM services. A practice is expected to conduct 20 minutes of chronic care management per patient per month for those with two or more chronic conditions expected to last at least 12 months or until death. The chronic conditions are defined as placing the patient “at significant risk of death, acute exacerbation/decompensation or functional decline,” with a “comprehensive care plan established, implemented, revised or monitored.”

Chronic care management is expected to be conducted by clinical staff “directed by a physician or other qualified healthcare professional.” A new code for valuation of CCM services to qualifying patients is established as GXXX1.

Whether electronic health record systems being used today are up to the task of supporting chronic care management is a matter of debate and CMS offers a compromise.

The agency acknowledges in the final rule that it heard from many stakeholders that the new CCM program was laudable but premature, as EHRs are not as interoperable as envisioned under the CCM program. While many practices are making information available to care teams in a timely manner, they may not be fully interoperable with other providers, CMS was told during public comment before finalizing the new payment rules for 2015.

Some stakeholders recommended CMS delay adoption of EHR certification criteria for CCM services or offer hardship exceptions for small or rural practices to enable them to bill separately for CCM services in the absence of having an interoperable EHR. One commenter suggested allowance for use of faxing and secure messaging technology in the furnishing of CCM services if practices have challenges with interoperability. Stakeholders also worried that certified EHRs would have other technological or business impediments to sharing data across systems and organizations. They further reminded federal policymakers of the very low success rate in meeting Stage 2 meaningful use measures, and some called for CMS to prioritize access over adoption of certified EHRs.

In response, CMS in the rule states it continues to believe that it is necessary to require certified EHRs as a condition for the separate CCM payment to ensure adequate capabilities to enable members of the care team to have timely access to information that informs the care plan. However, CMS agrees that requiring the most recent edition of certification criteria could be an impediment to broad use of the CCM service.

“Accordingly, we are modifying our proposal to specify that the CCM service must be furnished using, at a minimum, the edition(s) of certification criteria that is acceptable for purposes of the EHR Incentive Programs as of December 31st of the calendar year preceding each PFS payment year (hereinafter ‘CCM certified technology’) to meet the final core technology capabilities (structured recording of demographics, problems, medications, medication allergies, and the creation of a structured clinical summary),” according to the rule.

That means for CCM payment in calendar year 2015, practices can use either the 2011 or 2014 editions of certification criteria.

“Practitioners must also use this CCM certified technology to fulfill the CCM scope of service requirements whenever the requirements reference a health or medical record,” according to the rule. “This will ensure that requirements for CCM billing under the PFS are consistent throughout each PFS payment year and are automatically updated annually according to the certification criteria required for the EHR Incentive Programs.”

The final rule, which will be formally published on Nov. 13, is available here.

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