Medicare Chronic Care Management Reimbursement: Clarifying EHR Use and Electronic Requirements

Thursday, October 22nd, 2015
This post was written by Patricia Donovan

Just one-fifth of U.S. physician practices participate in CMS's Chronic Care Management Program.

Nearly 70 percent of physicians nationwide admit they do not fully understand the Medicare Chronic Care Management (CCM) program, according to an August 2015 study by Smartlink Mobile Systems. The survey of 45,000 American physician practices determined that while 20 percent do participate in CCM, there is a great deal of confusion surrounding the CMS program designed to curb the cost of coordinating care for 34.4 million Medicare fee-for-service beneficiaries with two or more chronic diseases—particularly when it comes to meeting CCM’s electronic requirements.

The CCM initiative pays participating physician practices a monthly fee for twenty minutes of non-face-to-face patient care.

Earlier this year, Dr. Paul Rudolf, partner, Arnold & Porter LLP, and Nicole Liffrig, counsel, Arnold & Porter LLP, delved into CMS requirements and discussed approaches and challenges to meeting the CCM requirements, including a practice’s requirements for electronic health records (EHRs):

The CCM care plan is all the clinical staff needs to have access to in order to count time toward the 20 minutes. In terms of the EHR itself, the practice is only required for certain specified services within the Chronic Care Management. For example, the practice has to create a structured recording of demographics, problems, medications and allergies within the EHR, and then that information must inform the care plan. The care plan will include that type of information but doesn’t have to include everything that is in the EHR.

The practice also must put into the EHR a structured clinical summary record, which is discussed at some length in the final rule. In addition, the EHR must document that there’s written consent for the CCM services and all the other things the practice explained to the patient when the patient gave consent.

In addition, the care plan must be provided to the patient. That could be a hard copy or an electronic copy. The communication to and from home with community-based providers regarding their psychosocial needs and functional deficits also must be in the EHR.

Essentially, the electronic care plan is a distilled version of the EHR containing the pertinent information clinical staff would need to provide CCM services.

However, in spite of this interpretation, one Medicare contractor recently suggested that in order to count time toward the 20 minutes, the clinical staff has to have access to the EHR. We believe that is an incorrect interpretation of the rule. We believe the practitioners only need access to the electronic care plan.

The last thing I would like to mention about the EHR is that use of the EHR to provide care plans and other information to all off-site clinical staff and to other practitioners could theoretically raise privacy concerns. These are not new privacy concerns, but any practice that is going to provide CCM services needs to be cognizant of potential HIPAA issues and make sure they are in compliance. One thing that can be done in this regard is to have the individuals with EHR access sign business associate agreements.

Source: Chronic Care Management Reimbursement Compliance: Physician Requirements for Value-Based Revenue

http://hin.3dcartstores.com/Chronic-Care-Management-Reimbursement-Compliance-Physician-Requirements-for-Value-Based-Revenue_p_5027.html

Chronic Care Management Reimbursement Compliance: Physician Requirements for Value-Based Revenue sets the record straight on CCM reimbursement compliance, offering strategies for navigating obstacles and meeting requirements. In this 25-page resource, attorneys Dr. Paul Rudolf, partner, Arnold & Porter LLP, and Nicole Liffrig, counsel, Arnold & Porter LLP, drill down into chronic care management requirements outlined in the 2015 Medicare Physician Fee Schedule.

Tags: ,

Related Posts:





Comments are closed.