Archive for the ‘chiropractic EHR’ Category

The Final Word on Chiropractic EHR Stimulus Dollars (For Now)

by Tom Necela on July 27th, 2010 in Business, Documentation, EHR / EMR, chiropractic EHR, chiropractic EMR, chiropractic documentation, compliance

Reading time: 3 – 4 minutes

The recent release (July 16, 2010) of the “Final Rule” regarding Meaningful Use criteria and EHR (Electronic Health Records) Financial Incentives has certainly prompted lots of questions from many chiropractors about how to obtain stimulus dollars for their EHR / EMR systems and what they need to do to qualify.

Below is a summary of some key points regarding EHR eligibility for those of you who don’t care to read the original documents or fact sheets on Meaningful Use and EHR Financial Incentives in their entirety:

  • Meaningful Use Criteria which establish eligibility for financial incentives are for EHR Certified programs only. Translation: if your EHR is not certified, you may not receive any financial stimulus.  Many EHR companies are advertising that they are “eligible” for certification, although this is not the same as being certified.  Buyer beware!
  • You know only need to complete 20 of the 25 Meaningful Use Objectives/Measures as defined in the Final Rule issued by CMS.  Even though you may “defer” 5 of these requirements, this is still an ambitious list for most practitioners in order to qualify for the funds. (See my previous blog post “The 25 Meaningful Use Criteria for Chiropractic EMR Systems” for a full list of criteria)
  • The completion of these Objectives/Measures fulfills Stage 1 requirements only (which make you eligible for the financial incentive portion).  Stage 2 and Stage 3 objectives exist, but the exact requirements and penalties are not as well defined.
  • Chiropractors are Eligible Professionals that may qualify for the EHR financial incentives
  • Chiropractors may be eligible for EHR financial incentive payments as early as 2011; payments can proceed for up to 5 years.
  • The total financial payments that chiropractors are eligible to receive is a maximum of  $44,000 over a 5 year period or equal to 75% of Medicare allowable charges for covered professional services furnished by the chiropractor in an eligible year.  This is perhaps the biggest criteria EHR companies fail to mention.  In other words, in one given year, you can receive up to $18,000 IF (and only if) you provide at least $24,000 worth of covered services (based on allowable charges) to Medicare patients.  On the other hand, if you have a small Medicare practice, your eligible financial incentives will be reduced accordingly and capped at 75% of the allowable charges for your covered services (which, in chiropractic, is CMT only).  Do the math to see if your practice qualifies for anywhere near the $44K amount.

The Bottom Line

My final opinion is not changed by the “final rule” criteria.  I would highly recommend that most offices switch to some form of electronic health records.  However, this advice is NOT based on the presumption that you are doing so to capture any potential financial stimulus incentives.  Rather, migrate to EHR because of its potential to improve your documentation, level of care and overall recordkeeping.

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Medicare Releases Chiropractic Medical Review Findings for the 1st Quarter

by Tom Necela on April 6th, 2010 in Audits, Chiropractic Audits, Coding, Documentation, EHR / EMR, Medicare, chiropractic EHR, chiropractic EMR, chiropractic coding, chiropractic documentation

Reading time: 4 – 6 minutes

detective

Recently, a Medicare carrier (Palmetto GBA) released their 1st Quarter results of Medical Reviews they have been conducting.  Even though Palmetto is only one of several carriers who administer claims on behalf of Medicare, their findings are relevant to chiropractors and, in my experience, reflective of trends across the chiropractic profession at large.

The goal of the medical review program is to reduce payment errors by identifying and addressing documentation and billing errors concerning coverage and coding. In their reviews, Palmetto GBA identified ten problem areas for the first quarter of 2010. These areas were as follows:

  1. Split/shared visits
  2. Signatures
  3. Labels/Diagnostic Testing
  4. Hospital & Nursing Facility Discharge Services
  5. Chiropractic Services
  6. Therapy Services
  7. Individual Psychotherapy Services
  8. Evaluation & Management Services
  9. Legibility

10.  Teaching Physician Services.

Please note this is not an all-inclusive list but does reflect the majority of documentation issues discovered during the review process.  Of this list, however, three items have direct application to chiropractic reimbursements in the Medicare program.

So let’s discuss these three “Frequently committed errors”:

  1. Signatures.  Put simply, Medicare requires an “identifier” for services provided or ordered.  That identifier is your signature – either in handwritten or electronic form.  Signature stamps in your documentation are not acceptable per Medicare Signaure Requirements (See section 3.4.1.1 B) Quite frankly, this is so basic that it is ridiculous that it even makes the top ten. Apparently, despite its simplicity, most physicians seem to overlook it.
  1. Chiropractic Services.  As a relatively small profession, we should not even make the top ten hit list.  We did, however, so now it is our responsibility to correct these problems asap as a profession.  Palmetto found chiropractic documentation to be lacking in the area of Treatment Plans.  More precisely, chiropractors were missing treatment plans with specific objective, measurable treatment goals. Follow thru with these specific objective treatment goals on subsequent visits was also often omitted.  Difficult?  Not very.  Documented?  Apparently, not very often.  Can you fix this, doctor?  Definitely!
  1. Legibility.  If this is not the biggest commercial for EMR, I don’t know what is!  Again, there is no reason any physician should be getting dinged for this one.  Alas, I have seen many of your notes and I sadly agree, that they are barely legible, sometimes only to the highly trained eye (yours and that of your longstanding staff) – and sometimes, even you cannot decipher your own notes.  Put simply, if your notes cannot unquestionably be read by a third-party without eliciting a migraine or use of some special telescopic lens, it is high time to get on EMR.  There are plenty of good systems out there.  In fact, ANY system that produces legible documentation is better than marginal handwriting – and I have yet to see an EMR system that fails to product legible documentation!

In summary, we chiropractors need to get our act together pronto – not only for Medicare, but for all third party payers.  The items above are not difficult to fix, but I realize that some of you are overwhelmed by how much work you have to do to bring your documentation, billing and coding up to acceptable standards.  Others may be so consumed with building your business that you literally don’t have time to look up and see the arrow sailing directly at the target on your chest.  And some of you are just plain tired of putting out the fires in all these areas due to a lack of solid systems that both maximize your reimbursements and minimize your audit risk.

The good news is: help is available. And while it is a physical impossibility for me to assist  all of you with these needs let alone answer the truckload of emails I receive per month on chiropractic billing, coding and documentation questions from random chiropractors at large!  But I am willing to offer a FREE, no obligation look under the hood of your practice for those of you willing to invest the time and effort into completing a Practice Analysis Questionnaire.  Download it, complete it, fax it in today and take a concrete step towards improving your practice, your business, your piece of mind and your life.

To Your Success!

Tom Necela, DC, CPC, CPMA

P.S.      Not sure what can be done with YOUR practice?  Take a look at what my clients have to say about the transformations they have achieved in their practice!

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The 25 Meaningful Use Criteria for Chiropractic EMR Systems

by Tom Necela on February 15th, 2010 in Business, Documentation, EHR / EMR, chiropractic EHR, chiropractic EMR, chiropractic business, chiropractic documentation

Reading time: 8 – 14 minutes

chasing-money

Adopting an electronic medical records (EMR) system can net you up to $44,000 in government incentive money. Or can it?

Some of the most frequently asked questions I received in 2009 (which still continues through 2010) is in regards to how to select an EMR system and the stimulus funds that potentially go with EMR implementation.

The problem?

All stimulus incentives hinged on practices adopting “meaningful use” of the EMR systems in question.  The problem? Up until December 2009, “meaningful use” was left undefined!

In other words, you could not get the money unless you were using EMR according to certain set criteria but no one went on record to establish exactly what those criteria were!

Unfortunately, the cloud was not exactly lifted this past December because the proposed rules for “Meaningful Use” are 556 pages long! Worse yet, industry experts don’t expect the final rule to be much different so knowing the proposed rule is essential to meeting meaningful use and getting paid.

So, then, how does one crack the mystery code and define meaningful use?  Lost in those 556 pages are a total of 25 requirements your practice must meet to achieve meaningful use. Don’t worry, I will spare you the trouble of reading the electronic equivalent of War and Peace (which is far more difficult to understand and much less entertaining) and summarize the 25 points below.

But let me cut to the chase.  For those of you who have recently purchased an EMR system or who are considering a purchase, don’t bank on getting those stimulus dollars just yet.

For those of you who are still considering getting an EMR system, let me go on record and state that I think that is a great idea for most practices.  However…don’t purchase one just because you feel the stimulus dollars are going to be rolling in afterward.

Purchase one with the intent of having a system improve your clinical documentation, practice management and overall efficiency.  Most will do that, provided you choose the right system to suit your needs.

Can’t decide which system to choose?

Given that you should take stimulus dollars out of the equation, there are certainly other factors to consider in choosing the right system for you.  Before you make a $10,000 mistake, perhaps you should consider investing less than 1% of that figure into my “How to Choose a Chiropractic EMR System audio program.

This 1.5 hour program (on 3 Audio CD’s) walks you through the thought process of how to make an intelligent decision on purchasing the right system for your practice.  I won’t come out and tell you to buy X, Y or Z but teach you how to shop and the tough questions you should be asking to make sure that you are getting the right system.

Frustrated with Your Own System?

It’s not too late to start over and think strategically about what will be a better fit for you and your practice.  I see far too many chiropractors who have expensive EMR systems collecting dust because they abandoned ship out of frustration and went back to paper.

There was a reason you chose to get EMR, you should find a system that you can actually use – they ARE out there!  Again, before you run out and buy another program, consider a small investment in strategy, some collective wisdom and a system to make a good purchase – my “How to Choose a Chiropractic EMR System” audio program accomplishes all of these.

And now, as promised, here are the 25 “Meaningful Use” Criteria for eligible providers. (These criteria were taken from the proposed rule: Medicare and Medicaid Programs; Electronic Health Record Incentive Program.)

The List: 25 Meaningful Use Criteria

1- Objective: Use computer physician order entry (CPOE)
Measure: CPOE is used for at least 80 percent of all orders

2 -Objective: Implement drug-drug, drug-allergy, drug- formulary checks
Measure: The EP has enabled this functionality

3 – Objective: Maintain an up-to-date problem list of current and active diagnoses based on ICD-9-CM or SNOMED CT®
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry or an indication of none recorded as structured data

4 – Objective: Generate and transmit permissible prescriptions electronically (eRx)
Measure: At least 75 percent of all permissible prescriptions written by the EP are transmitted electronically using certified EHR technology

5- Objective: Maintain active medication list
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry (or an indication of “none” if the patient is not currently prescribed any medication) recorded as structured data

6- Objective: Maintain active medication allergy list
Measure: At least 80 percent of all unique patients seen by the EP have at least one entry (or an indication of “none” if the patient has no medication allergies) recorded as structured data

7 – Objective: Record demographics.
Measure: At least 80 percent of all unique patients seen by the EP or admitted to the eligible hospital have demographics recorded as structured data

8 – Objective: Record and chart changes in vital signs
Measure: For at least 80 percent of all unique patients age 2 and over seen by the EP, record blood pressure and BMI; additionally, plot growth chart for children age 2 to 20

9 – Objective: Record smoking status for patients 13-years-old or older
Measure: At least 80 percent of all unique patients 13-years-old or older seen by the EP “smoking status” recorded

10 – Objective: Incorporate clinical lab-test results into EHR as structured data
Measure: At least 50 percent of all clinical lab tests results ordered by the EP or by an authorized provider of the eligible hospital during the EHR reporting period whose results are in either in a positive/negative or numerical format are incorporated in certified EHR technology as structured data

11 – Objective: Generate lists of patients by specific conditions to use for quality improvement, reduction of disparities, research, and outreach
Measure: Generate at least one report listing patients of the EP with a specific condition

12 – Objective: Report ambulatory quality measures to CMS or the States.
Measure: For 2011, an EP would provide the aggregate numerator and denominator through attestation as discussed in section II.A.3 of this proposed rule. For 2012, an EP would electronically submit the measures are discussed in section II.A.3. of this proposed rule.

13 – Objective: Send reminders to patients per patient preference for preventive/ follow-up care
Measure: Reminder sent to at least 50 percent of all unique patients seen by the EP that are 50 and over

14 – Objective: Implement five clinical decision support rules relevant to specialty or high clinical priority, including for diagnostic test ordering, along with the ability to track compliance with those rules
Measure: Implement five clinical decision support rules relevant to the clinical quality metrics the EP is responsible for as described further in section II.A.3

15 – Objective: Check insurance eligibility electronically from public and private payers
Measure: Insurance eligibility checked electronically for at least 80 percent of all unique patients seen by the EP

16 – Objective: Submit claims electronically to public and private payers.
Measure: At least 80 percent of all claims filed electronically by the EP

17 – Objective: Provide patients with an electronic copy of their health information (including diagnostic test results, problem list, medication lists, and allergies) upon request
Measure: At least 80 percent of all patients who request an electronic copy of their health information are provided it within 48 hours

18 – Objective: Provide patients with timely electronic access to their health information (including lab results, problem list, medication lists, allergies)
Measure: At least 10 percent of all unique patients seen by the EP are provided timely electronic access to their health information

19 – Objective: Provide clinical summaries to patients for each office visit
Measure: Clinical summaries provided to patients for at least 80 percent of all office visits

20 – Objective: Capability to exchange key clinical information (for example, problem list, medication list, allergies, and diagnostic test results), among providers of care and patient authorized entities electronically
Measure: Performed at least one test of certified EHR technology’s capacity to electronically exchange key clinical information

21 – Objective: Perform medication reconciliation at relevant encounters and each transition of care
Measure: Perform medication reconciliation for at least 80 percent of relevant encounters and transitions of care

22 – Objective: Provide summary care record for each transition of care and referral
Measure: Provide summary of care record for at least 80 percent of transitions of care and referrals

23 – Objective: Capability to submit electronic data to immunization registries and actual submission where required and accepted
Measure: Performed at least one test of certified EHR technology’s capacity to submit electronic data to immunization registries

24 – Objective: Capability to provide electronic syndromic surveillance data to public health agencies and actual transmission according to applicable law and practice
Measure: Performed at least one test of certified EHR technology’s capacity to provide electronic syndromic surveillance data to public health agencies (unless none of the public health agencies to which an EP or eligible hospital submits such information have the capacity to receive the information electronically)

25 – Objective: Protect electronic health information maintained using certified EHR technology through the implementation of appropriate technical capabilities
Measure: Conduct or review a security risk analysis in accordance with the requirements under 45 CFR 164.308 (a)(1) and implement security updates as necessary

The Sum Total

Again, not all these criteria seem terribly relevant to chiropractic and quite frankly, I would love to see how some EMR providers can define these in such a way that they can guarantee stimulus dollars.

My recommendations:

  1. If you already are using EMR, approach your provider with this list and see how their system can complete the measures to obtain each objective so that you at least have a chance at getting some stimulus funding.
  2. If you do not yet have an EMR system, use these criteria as part of your questions to each system that you are considering for purchase, particularly if they are claiming to get you some stimulus funding.  Also, consider purchasing “How to Choose a Chiropractic EMR System” Audio series to further assist you in making a wise choice of systems that will fit your needs.
  3. If you are unsatisfied with your current system, consider shopping for another and following the instructions in #2 – but do not purchase your new system just because you think you are going to get the HITECH dollars!

Best wishes for continued success!

Tom Necela, DC

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