CMS to contractors: Watch for inappropriate use of EHR templates

Physicians should expect more scrutiny of their claims, now that the Centers for Medicare & Medicaid Services has instructed its payment review contractors--including Medicare administrative contractors, recovery audit contractors, and zone program integrity contractors--to be on the lookout for providers using electronic health record template shortcuts that fail to provide adequate information.

The revised instructions, effective Dec. 10, require contractors to consider all permanent medical record entries, even those created using limited space templates, and extract any usable information relevant to the claim. In the past, contractors could consider any documentation to support payment determinations.  

The revised instructions state that CMS doesn't prohibit the use of templates to facilitate record keeping, nor does it approve of or endorse any particular templates. Electronic records may involve any type of interface, not just sophisticated ones, with clinical decision and documentation support prompts. Templates can even be paper-based.

However, the agency discourages the use of templates that provide limited options for the collection of information, such as check boxes or predefined answers, or limited space to enter information.

"Claim review experience shows that that limited space templates often fail to capture sufficient detailed clinical information to demonstrate that all coverage and coding requirements are met," CMS says in the revised instruction. "Physician ... should be aware that templates designed to gather selected information focused primarily for reimbursement purposes are often insufficient to demonstrate that all coverage and coding requirements are met. This is often because these documents generally do not provide sufficient information to adequately show that the medical necessity criteria for the item/service are met." 

The instruction change likely reflects concerns that EHR shortcuts enable providers to bill improperly, which have received widespread attention in recent months. U.S. Department of Health & Human Services officials have made it clear that EHR billing fraud will not be tolerated. The Office of the National Coordinator for Health IT also is investigating inappropriate EHR billing accusations, and the Office of Inspector General has included this issue in its 2013 work plan.

To learn more:
- here's the revised instruction