Physician practices providing chronic care management (CCM) to Medicare beneficiaries will be required to use EHR software certified to at least 2014 Edition Meaningful Use requirements if a new proposed rule is adopted. The proposed rule was released on July 3 and published in the Federal Register on July 11.
Last year, CMS finalized a separate payment, outside of a face-to-face visit, for managing the care of Medicare patients with two or more chronic conditions beginning in 2015. Chronic care management services include regular development and revision of a plan of care, communication with other treating health professionals, and medication management.
CMS indicated in the July 11 proposed rule that it was seeking improved communication and coordination between all care providers involved in CCM, including those providing care outside normal business hours, and that a care plan should be able to be shared with care team members outside the practice.
CMS said in its statement that “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.
CMS went on to say that it believes effective care management requires regular monitoring of a patient’s health status, needs and services, as well as frequent communication and exchange of information with the patient and the treating providers.
Lack of certified EHRs could prove a challenge
This new EHR requirement could prove problematic for practices providing CCM, given that so few EHRs have been certified to the 2014 standards. However, CMS is demonstrating that it intends to push forward with requiring interoperability—as it should—and this means requiring electronic medical records certified to the 2014 standards.
The best course for practices billing for CCM is to adopt an EHR that is already 2014 certified; using EMR software that has received 2014 Meaningful Use certification will ensure that your practice is ready for these CCM requirements by CMS and any additional EHR-related requirements for other programs.
In fact, this indicator of CMS’ commitment to the 2014 standards, along with the need for a 2014-certified EHR for 2015 Meaningful Use attestation, reinforce the need for all practices to make sure their EHR systems are certified to the latest standards, in spite of the proposed rule for 2014 allowing attestation with either 2011 or 2014 certified systems.
HealthFusion’s MediTouch® EMR software is 2014 Meaningful Use certified and was one of the first five complete ambulatory electronic medical records to receive certification.
A fact sheet detailing proposed policy and payment changes to the Medicare Physician Fee Schedule for 2015 is available online. CMS will accept comments on the proposed rule until Sept. 2, 2014.
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