CMS may require EHRs for payment of chronic care management

The Centers for Medicare & Medicaid Services' expectation that physicians transition to electronic health records continues to rise with EHRs increasingly integrated into CMS' 2014 physician payment rule.

The rule, released Nov. 27 and scheduled to be published in the Federal Register Dec. 10, does not require physicians to adopt EHRs. However, it specifies that chronic care management and care coordination includes inputting the full list of problems, medications and allergies in the physician's EHR. The rule also finalizes alignment of EHR incentive program reporting with other reporting initiatives, such as PQRS.

More controversial was CMS' suggestion in the rule that the standards for future chronic care management should include required use of an EHR that meets Meaningful Use, and that the EHR "must be integrated into the practice to support access to care, care coordination, care management, and communication."

CMS reports in the final rule that many commenters, while generally supporting the value of EHRs for chronic care management, addressed concern with this suggestion for a multitude of reasons. Some of those concerns included questioning the need for an EHR at all. Others focused on the timing of such a requirement, noting that:

  • It would be better to use Meaningful Use as a standard;
  • Such a standard be delayed until interoperability had increased;
  • Small and rural practices didn't yet have the capability;
  • Such a requirement "interfered with the physician's prerogatives and practice."

CMS opted not to rule on this proposal yet, stating only "[w]e appreciate commenters' suggestions and will consider these comments for any future rulemaking on this topic." CMS did not indicate when such a rule would be forthcoming.

This is not the first time that stakeholders have expressed concern with the speed at which CMS is spurring adoption of EHRs and moving to Stage 2 of the Meaningful Use program, with stakeholders and even some in Congress suggesting that the industry isn't yet ready for the transition.   

To learn more:
- read the rule (.pdf)