Medicare Compliance & Reimbursement

Beware: Too much cutting and pasting could wound you.

Your electronic health records (EHRs) could soon need an upgrade.

RTI International (RTI) just released a draft version of anti-fraud standards for EHRs. The standards could put more pressure on doctors to support evaluation & management (E/M) levels in documentation. RTI convened a panel of experts to suggest ways that EHRs could guard against fraud and incorrect billing. The experts said EHRs should:

· Make sure cut-and-pasted documentation keeps the original time-and-date stamp from the records it was cut from (but if the doctor cuts and pastes from one patient's record to another, the pasted documentation won't include the first patient's name or Medicare number).

· Flag records where the doctor is choosing an E/M level the documentation doesn't support. Current standards from the Certification Commission for Healthcare Information Technology say that EHRs should "prompt for data required to determine appropriate [E/M] codes if such data is not present in encounter data."

The RTI experts said that it's appropriate for EHRs to calculate an E/M code based on the doctor's documentation. But it's not okay for EHRs to suggest that the doctor could raise the E/M level if he or she added certain additional documentation.

· Include audit functions, and allow auditors to access notes.
· Require the doctor to include the correct national provider identifier (NPI) to prevent confusion about who entered the documentation.
· Check the credentials of each user to make sure they're qualified for the services they're providing.
· Support security measures such as strong passwords or biometrics.
· Allow auditors to view how the user entered each visit note (by voice, by keyboard, or by cut-and-paste).
· Prevent unauthorized printing and viewing of patient records by keeping track of all transfers.
· Allow patients to access the EHR and comment on it, so patients can help prevent fraud.
· Create a link from the claim to the documentation that supports it

"There needs to be some point in the process of documenting an encounter when that documentation cannot be altered without retaining an audit trail of the original entry," the draft standards say. In other words, the system should note if anyone made changes after the doctor "signs" the note or the practice "closes" the encounter.

What's next: Once lawmakers finalize the standards, RTI will work with organizations that certify EHR software to incorporate them. The organizations' members will vote on the standards and may make some changes, says Colleen McCue, the RTI project director.