Do practices need to obtain consent from patients to enroll in the new Medicare Chronic Care Management program?

Yes. Chronic Care Management, LLC provides practices a variety of ways to obtain appropriate consent (electronic, written, etc.).

Is Chronic Care Management, LLC’s platform a medical record?

No. Chronic Care Management, LLC provides a transformative, complete time tracking and audit trail solution coupled with robust care planning tools to ensure compliance with the Centers for Medicare and Medicaid Services FY 2015 Final Rule when used alongside an ONC IT Certified Electronic Health Record. Your existing certified EHR will satisfy the final core technology capabilities (structure recording of demographics, problems, medications, medication allergies, and the creation of a structure clinical summary) that CMS requires.

Isn’t 24/7 access to the electronic care plan required?

Yes, and Chronic Care Management, LLC provides 24/7 access to the entire care team via a secure web portal, enabling each patient’s care plan to be viewed and updated at any time.

I’m confused by the language stating that a “certified EHR” must be used.

A certified EHR must be used as the principal medical record of a practice to qualify for CCM activities under Medicare. But, CMS was explicit in its final rule that “certified EHR technology is limited in its ability to support electronic care planning at this time, and that practitioners must have flexibility to use a wide range of tools and services beyond certified EHR technology now available in the market to support electronic care planning.” As such, development of a care plan should be informed by data stored in a certified EHR, but it is not required to be used to create or modify it.

How can a practice track all the time that it performs CCM for its patients?

Chronic Care Management, LLC provides robust time tracking capabilities, assigning the time staff actually spent doing care management for patients, then tallying the time to alert your billing department which patients exceeded the twenty minute threshold each month.

How can the care plan be exchanged?

Chronic Care Management, LLC exchanges care plans in an efficient and complaint manner. From CMS’s Final CY 2015 Rule: “To satisfy this element, practitioners must at least electronically capture care plan information; make this information available on a 24/7 basis to all practitioners within the practice who are furnishing CCM services whose time counts towards the time requirement for the practice to bill the CCM code; and share care plan information electronically (other than by facsimile) as appropriate with other practitioners and providers who are furnishing care to the beneficiary. We are not requiring practitioners to use a specific electronic solution to furnish the care plan element of the CCM service, only that the method must be electronic and cannot include facsimile transmission. Similarly, we are not requiring practitioners to use a specific tool or service to communicate clinical summaries in managing care transitions, as long as practitioners transmit the clinical summaries electronically, with exception of faxing which will not fulfill the requirement for exchange of a summary care record. However practitioners must format their clinical summaries according to, at a minimum, the standard that is acceptable for the EHR Incentive Programs as of December 31st of the calendar year preceding each PFS payment year.”