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Meaningful Use Standards for EHRs/EMRs – Do They Mean $0 for Chiropractors?
If you are a glutton for punishment, go ahead and read the 136 pages of
meaningful use guidelines on the Internet. If you like technical documents
full of doublespeak, this is for you. Unfortunately, meaningful use may impact
a chiropractor's ability to qualify for reimbursement promised by the economic
stimulus package. That is the bottom line.
As part of the ongoing governmental push toward EHRs (electronic health
records), the government has designed a set of criteria that each EHR must meet
in order to qualify for government reimbursement through the stimulus package
being offered through Medicare and Medicaid. Unfortunately, while the
government has included the chiropractic profession as reimbursable
practitioners, the guidelines for a certified EHR fall far outside the scope of
the chiropractic practice. At this point in time, there is no certifying agency
for chiropractic EHR's. In fact, if you call CCHIT - the one and only
certifying agency so far (www.cchit.org),
they have no certification process for chiropractic EHRs. If you look at the
meaningful use guidelines, you can see why certification for chiropractic EHRs
is lacking. Let's take a look at the guidelines.
Computerized Provider Order Entry
The EHR must provide for computerized order entry for medications, laboratory,
radiology and provider referrals. While the chiropractic profession will order
x-rays and may refer patients to other providers, they do not prescribe
medications and usually do not get involved with laboratory tests. A good
portion of the guidelines cover electronic prescription and the ability to
generate alerts for drug interactions and contraindications. There are two or
three pages of meaningful use guidelines specifically related to electronic
prescriptions. In addition, the EHR has to be able to order lab tests and
receive the results as structured data. Again, this information is not useful
or even allowed in many states according to the chiropractic scope of practice.
Record Demographics and Changes in Vital Signs
To be certified, an EHR must enable the office to record and modify demographic
data including preferred language, insurance type, gender, race, ethnicity and
date of birth. In addition, vital signs such as height, weight, blood pressure,
temperature and pulse must be able to be recorded and modified. The system must
automatically calculate and display the body mass index based on the patient's
height and weight. An interesting addition to the requirements is the fact that
the EHR must record smoking status for patients 13 years or older. It must be
able to indicate whether the patient is a current smoker, former smoker or
someone who has never smoked. It is an indication that prevention will be
addressed by future guidelines. Once the EMR or EHR has gathered this
information, it must be able to produce lists of patients based on the
demographic data and specific diagnoses.
Report Quality Measures to CMS
While the EHR is expected to be able to report quality measures to CMS (the
governing body for Medicare and Medicaid), there are no specifications
available.
Interaction with Patients
As part of the meaningful use guidelines, the EHR is expected to be able to send
preventive or follow-up reminders to patients based on demographic data,
medications or diagnosed conditions. In addition, the EHR must provide an
electronic copy of the patient's record on request by the patient. It
specifically states that the EHR must “Provide patients with timely electronic
access to their health information (including lab results, problem list,
medication lists, allergies) within 96 hours of the information being available
to the eligible professional.” What all that means is this: the EHR must
include the ability to communicate information directly to the patient after a
service is rendered. For a chiropractic office, does this mean that you need to
make your office notes available to the patient online after each visit? That
seems to be what it is saying in this statement: “Provide clinical summaries for
patients for each
office visit.” Many of the chiropractic EHRs on the market are not equipped for
direct interaction with the patient. It would seem that much of this
interaction will have to take place behind a secure patient portal.
Check Insurance Eligibility and Submit Claims Electronically
A small portion of the guidelines indicates that the EHR must be capable of
checking insurance eligibility and submitting claims electronically for all
carriers, not just Medicare and Medicaid. Again, this is a departure from the
normal use of an EHR. It is usually the practice management portion of the
software program that performs these functions, not the electronic health
record.
Implement 5 Clinical Decision Support Rules
While the first portion of this rule deals specifically with medications and
alerts regarding contraindications, the second portion reads as follows:
“automatically and electronically generate and indicate (e.g., pop-up message or
sound) in real time, alerts and care suggestions based upon clinical decision
support rules and evidence grade.” Once the alert has been generated, the EHR
must track the number of alerts responded to by the user. How does this apply
to a chiropractic EHR? I wish I had an answer to this one but its applicability
escapes the author at this time.
Capability of Transmitting and Synchronizing Data
The EHR must be capable of transmitting and receiving data regarding
medications, lab tests and results and immunizations. In addition, the EHR must
transmit immunization data to appropriate public health agencies. Again, most
of this rule falls outside the scope of practice for chiropractic.
Protection of Health Care Data
A certified EHR must display the ability to assign a unique name or number to
each patient. It must assign levels of security that allows access by users
within a clinic. It must provide for the encryption and decryption of health
care data. It must have a means of verifying that the user requesting data has
met the criteria for accessing the data. In other words, the data must be
secured by passwords and encryption so the person who cleans the office cannot
access patient data (unless the “office cleaner’ is the doctor!.)
The Dilemma Exposed
As a chiropractor, do you want to use a computerized electronic health record
built for the medical profession? You will have to wade through pages and pages
of screens that do not apply to your patients to record your encounters. Even
more daunting, do you want to pay at least $40,000 for this capability? The
large medical companies offer financing for their higher priced models but do
you want to pay for functionality that you will never use just to qualify for
the stimulus reimbursement? That is a question that you must ask yourself.
Because the meaningful use guidelines are so stringent, many of the smaller
companies offering chiropractic EHRs cannot afford to accommodate the medical
guidelines concerning electronic prescriptions, lab tests and immunizations just
to sell their chiropractic versions. Quite frankly, they shouldn't be forced
to. If a company has built an EHR specifically for the chiropractic profession,
there should be a path to certification if the government did, in fact, intend
that chiropractors qualify for reimbursement. Of course, maybe the language of
the law was never really intended to be all-inclusive. That is a question that
I will leave you to answer.
About the Author
This article was written by Marilyn K Gard, MBA, CEO of
ClinicPro chiropractic software and ICER-2-GO LLC. Marilyn has been involved
with the chiropractic profession for 30 years, conducting chiropractic insurance
seminars, writing professional articles and running a software development
company. ClinicPro software currently offers an electronic medical record
program which includes patient education in partnership with the New Renaissance
organization. Marilyn can be reached at
Marilyn@clinicpro.com or 928-203-0854.
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