CMS proposal would require EHRs for payment of chronic care management

CMS has followed through with its stated intention of requiring electronic health records for payment of chronic care management (CCM), proposing in its 2015 physician payment rule that physicians receive a separate payment for CCM services, but only if they are using at least the 2014 edition of certified EHR technology.

The proposed rule, released July 3 and scheduled to be published in the Federal Register July 11, does not create a new set of standards for CCM services but adds the EHR requirement as a new scope of service for providers.

"After gathering input from stakeholders, we believe that requiring those who furnish CCM services to utilize electronic health record technology that has been certified by a certifying body authorized by the National Coordinator for Health Information Technology will ensure that practitioners have adequate capabilities to allow members of the interdisciplinary care team to have immediate access to the most updated information informing the care plan," CMS says in the proposed rule. 

"Furthermore, we believe that requiring those that furnish CCM services to maintain and share an electronic care plan will alleviate the development of duplicative care plans or updates and the associated errors that can occur when care plans are not systematically reconciled." 

Other requirements needed to bill for CCM services include 24/7 access to care, creation of a patient centered plan document and additonal specific billing obligations.

The 2014 physician payment rule did not require physicians to adopt EHRs, but did specify that CCM and care coordination includes inputting the full list of problems, medications and allergies in the EHR--and had suggested that standards for future CCM should include required use of EHRs that meet Meaningful Use.

Many who commented on the 2014 rule expressed concern about requiring EHRs for CCM, recommending that it be delayed until more physicians had achieved Meaningful Use and interoperability had improved.

The proposed rule also relaxes several requirements of the Meaningful Use incentive program itself. CMS would no longer require that eligible professionals ensure their certified EHR product has been recertified, allow reporting flexibility where certain errors in a clinical quality measure have been discovered, and reduce the reporting obligations on comprehensive primary care initiative practice sites.

Comments on the proposed 2015 fee schedule are due Sept. 2.

To learn more:
- read the rule
- here's the fact sheet

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