The liveliest debate among chiropractors regarding the EHR Incentive “Stimulus” Program revolves around drugs, naturally! With rare exception, medication prescription does not fall within chiropractic’s scope of practice. Why then, must a chiropractor use an EHR with all the drug bells and whistles or maintain an active medication list on his or her patients to be eligible for stimulus money?
NOTE: This article has the most up-to-date information at the time of this writing; however, the government program is continually evolving, so please join me for the latest news update at my regularly scheduled educational webinars at www.acomhealth.com/EHRwebinar.
Let’s start at the top, the Final Rule
On July 28, 2010, after much debate and public comment, CMS released 42 CFR Parts 412, 413, 422 et al. Medicare and Medicaid Programs; Electronic Health Record Incentive Program; Final Rule. Essentially, this 276 page document is the EHR Incentive Program’s Bible. It says, an EP (Eligible Professional), that’s you, must utilize a single “complete” certified EHR, or multiple “modular” certified EHRs when combined cover 100% of the required Meaningful Use (MU) measures. The government’s intent is to ensure the decision of whether or not any particular MU measure is used, or not used, remains in the hands of the provider, not the vendor. As a result, software vendors who chose to attain “complete” certification status – so doctors would only need to purchase a single EHR – had to incorporate all drug related MU measures into their product, including those related to drugs, even though their end users may never ePrescribe or make medication recommendations.
Side note: A glimmer of sunshine was written into the Final Rule allowing EHR vendors to “turn off” the ePrescribe functionality as long as it could be activated at a provider’s request. This language was extremely important from the chiropractic perspective because it meant chiropractors, other than those few who prescribe drugs, wouldn’t have to pay for software functionality which doesn’t apply to them and is actually illegal to use.
What You Must do to Qualify for Incentive Payments
Now let’s look beyond vendor requirements and into what the provider must do to qualify for incentive payments. If you read my previous article, Meaningful Use – In A Nutshell, you’ll know there are 25 MU measures. Of these, seven are drug related, but only three really matter: Drug Interaction Checks (Core #2); Active Medication List (Core #5); and Medication Allergy List (Core #6). Why? Because there is “no exclusion” for these measures! Therefore, all providers wishing to meet MU must complete all three to successfully attest.
No need to panic. Drug Interaction Checks must simply be “enabled,” or turned ON. Drug Interactions run automatically in the background of your software and alert you when two drugs on a patient’s medication list have known severe incidence of adverse effects (huge opportunity to educate patients here). Simple enough! Next, Medication and Medication Allergy Lists are both straightforward activities which you are “not required to update…at every contact with the patient” and you may use your “clinical judgment to decide when additional probing is required.” Super simple!
CPOE for Medication Orders (Core #1), ePrescribing (Core #4), and Drug Formulary Checks (Menu #1) are three more MU measures related to drugs, however, all three carry an exclusion for providers who write fewer than 100 prescriptions. Think of exclusions as exemptions, or immunity. So, unless you write more than 100 prescriptions, there’s no need to worry about these three drug measures at all, you’re excluded!
Medication Reconciliation (Menu #7) is the last of the seven MU measures related to drugs, however, it too is of little concern because it is a Menu item; meaning, you don’t need to report on it (remember, you only need to report on 5 of 10 Menu measures). Besides, other Menu items are recommended and less problematic. Plus, Medication Reconciliation has an exclusion you may qualify for if you are not the recipient of any “transitions of care” – a patient was referred to you by another provider.
Recap
There are seven MU measures related to drugs, but only three carry significance to DCs because they do not have exclusions. They are:
1. Drug Interaction Checks
2. Active Medication List
3. Medication Allergy List
Consequently, all providers, regardless of scope, must report on these three measures if they are to successfully meet MU and get a stimulus check. The good news is this: Even though your software must do it all, you don’t; and the abovementioned measures are reasonable and easy to complete when given the right EHR technology.
NOTE: This article has the most up-to-date information at the time of this writing; however, the government program is continually evolving, so please join me for the latest news update at my regularly scheduled educational webinars at www.acomhealth.com/EHRwebinar.
{ 2 comments… read them below or add one }
What do you mean your software does it all? Is there a “magical” software out there that knows patient information by them just walking through our doors? Someone, the doctors or the staff, has to input all this information. So first, you must gather all the information then second, you have to input all this information. Then, what are we supposed to do when we see something wrong? With limited scope of practice that most of us have, I can see some angry M.D., afraid he’s going to get sued because we told his patient about some precaution he missed, have us in front of the state board for practicing medicine. We are damned if we do and damned if we don’t.
Dr. Mike,
I appreciate your frustration, but offer that it is good news to patients to have systems in place that can enable you to make them aware of a potential problem. What you do with that information would be your choice.
With respect to “magical” softtware, there was no mention of “our software does it all” the portion of the article you’re referencing said:
We agree technology can only be an aid, not a silver bullet. Systems like ours do make the process much easier though, and even eliminate staff having to key and re-key data into the system with kiosks that enable patients to easily enter much of the information themselves.