EMR templates are coming under increasing fire of late, with regulators arguing that they’re not doing a good job of justifying the reimbursement that doctors are requesting. Now, in a move that can only be described as racheting up the pressure, CMS has revised its instructions to Recovery Audit Contractors (and their brethren) to demand that they look more closely at template documentation.
According to a report in EHR Intelligence, CMS has issued new orders asking RACs and other recovery contractors to review templates, extract usable data, and use that to determine whether reimbursement requests are legit. Specifically, it’s asking contractors to focus in on limited space progress note templates and open-ended progress note templates.
CMS isn’t asking providers to stop using templates, but it does seem fairly disapproving, particularly of limited space templates, which it regards as largely inadequate for payment purposes
“Review contractors shall remember that progress notes created with Limited Space Templates in the absence of other acceptable medical record entries do NOT constitute sufficient documentation of a face-to-face visit and medical examination,” the agency says in its contractor instructions.
The agency notes that templates using checkboxes and predefined answers to enter information generally don’t work. “Claim review experience shows that limited space templates often fail to capture sufficient detailed clinical information to demonstrate that all coverage and coding requirements are met,” the instructions note.
Well, there you have it. You’ve got an agency that’s coming down hard on the use of inadequate templates, but “does not endorse or approve any particular templates.” Seems like a recipe for disaster.
If CMS refuses to propose a specific template design, I say it’s incumbent on the industry to do so. With so much at stake, it’s time to lay out a design that vendors and providers can live with and hand it to CMS. Maybe that will spur the agency to take a stand.