A final rule on Medicare physician payments in 2015 emphasizes improved
chronic care management (CCM) and the supporting role of electronic health
records, and loosens certification criteria a little more.
Medicare will pay a separate fee to account for the “relative resources”
used in furnishing CCM services. A practice is expected to conduct 20
minutes of chronic care management per patient per month for those with
two or more chronic conditions expected to last at least 12 months or
until death. The chronic conditions are defined as placing the patient
“at significant risk of death, acute exacerbation/decompensation
or functional decline,” with a “comprehensive care plan established,
implemented, revised or monitored.”
Chronic care management is expected to be conducted by clinical staff “directed
by a physician or other qualified healthcare professional.” A new
code for valuation of CCM services to qualifying patients is established as GXXX1.
Whether electronic health record systems being used today are up to the
task of supporting chronic care management is a matter of debate and CMS
offers a compromise.
The agency acknowledges in the final rule that it heard from many stakeholders
that the new CCM program was laudable but premature, as EHRs are not as
interoperable as envisioned under the CCM program. While many practices
are making information available to care teams in a timely manner, they
may not be fully interoperable with other providers, CMS was told during
public comment before finalizing the new payment rules for 2015.
Some stakeholders recommended CMS delay adoption of EHR certification criteria
for CCM services or offer hardship exceptions for small or rural practices
to enable them to bill separately for CCM services in the absence of having
an interoperable EHR. One commenter suggested allowance for use of faxing
and secure messaging technology in the furnishing of CCM services if practices
have challenges with interoperability. Stakeholders also worried that
certified EHRs would have other technological or business impediments
to sharing data across systems and organizations. They further reminded
federal policymakers of the very low success rate in meeting Stage 2 meaningful
use measures, and some called for CMS to prioritize access over adoption
of certified EHRs.
In response, CMS in the rule states it continues to believe that it is
necessary to require certified EHRs as a condition for the separate CCM
payment to ensure adequate capabilities to enable members of the care
team to have timely access to information that informs the care plan.
However, CMS agrees that requiring the most recent edition of certification
criteria could be an impediment to broad use of the CCM service.
“Accordingly, we are modifying our proposal to specify that the CCM
service must be furnished using, at a minimum, the edition(s) of certification
criteria that is acceptable for purposes of the EHR Incentive Programs
as of December 31st of the calendar year preceding each PFS payment year
(hereinafter ‘CCM certified technology’) to meet the final
core technology capabilities (structured recording of demographics, problems,
medications, medication allergies, and the creation of a structured clinical
summary),” according to the rule.
That means for CCM payment in calendar year 2015, practices can use either
the 2011 or 2014 editions of certification criteria.
“Practitioners must also use this CCM certified technology to fulfill
the CCM scope of service requirements whenever the requirements reference
a health or medical record,” according to the rule. “This
will ensure that requirements for CCM billing under the PFS are consistent
throughout each PFS payment year and are automatically updated annually
according to the certification criteria required for the EHR Incentive
The final rule, which will be formally published on Nov. 13, is available here.