Electronic Certificates of Medical Necessity: An e-CMN Proposal

Introduction to e-CMN Technology

Medical billing can become a relatively painless process for personnel in a medical facility through the electronic filing of Certificates of Medical Necessity (e-CMNs). Manually filling out paperwork is time-consuming and not cost-effective. However, technological advancements in the area of medical billing are proving highly efficient. While many offices now fax CMNs, incorporating e-CMNs into the medical office and billing process decreases overhead costs, reduces paperwork, and helps substantially with the ongoing challenge of complying with ever-changing Medicare requirements. While each of these reasons is compelling enough to consider adopting e-CMNs, the increase in revenue is a major additional benefit — a direct result of the time reduction achieved through electronic filing.

Billy Tauzin, chairman of the U.S. House Committee on Energy and Commerce, clarified his concern to "reduce paperwork," and e-CMNs can help an agency reach that goal. The Practicing Physician Advisory Committee also identified the e-CMN issue as a priority among efforts to reduce unnecessary paperwork requirements for physicians. However, "only the full use of e-CMNs that includes acceptance of valid electronic signatures will allow all parties to reduce paperwork burdens" (Bachenheimer, 2002).

In September 2001, the Centers for Medicare and Medicaid Services revised the Medicare Program Integrity Manual (PIM) to include acceptance of faxed and electronic CMNs and other electronic communication between suppliers and physicians, while improving program integrity (Bachenheimer, 2002). The PIM included instructions for how e-CMNs should be created and used, and specified that they must "adhere to all privacy, security, and electronic signature rules and regulations. Additionally, e-CMNs must contain identical questions and wording to the paper CMS forms, including the same pagination, and identical instructions along with definitions as printed on the back of the hardcopy form" (McClinton, 2002).

The e-CMN is an automated electronic version of the same paper form used within a doctor's office. Because it is automated and paperless, the e-CMN is more time-efficient and cost-effective for a practice, allowing staff to concentrate on other vital issues such as patient care and office relations. Most doctor's offices are already equipped to complete e-CMNs with little additional cost to the overall budget. With basic Internet access and standard computer equipment that most offices already possess, the e-CMN may be filled out, electronically signed, and submitted to a secure site. After the home health care office receives a doctor's referral, an email is sent notifying the doctor to access the correct form.

The doctor accesses secure e-CMN information via encrypted Internet technology using a password-protected login, which also enables the doctor to electronically sign the form upon submission. The doctor and staff can be confident that all current and pending patient privacy and confidentiality regulations are satisfied. After completion, the e-CMN is electronically submitted and, within seconds, the filing process is complete.

Benefits of Incorporating e-CMN Technology

A doctor might ask how an e-CMN could benefit their organization. The benefits include increased time, productivity, compliance, and cash flow. Since a trusted member of the office staff may complete the e-CMN, the doctor is freed from manually signing forms, allowing more time with patients and freeing up capacity in an already demanding schedule. More patients may be seen, rounds might be completed sooner, and more critical tasks may be addressed when doctors are no longer burdened by paperwork.

Accuracy in filing is a significant advantage. HIPAA regulations have created new compliance concerns but also opportunities to modernize how medical business is conducted. This has driven updates and technology upgrades in many offices where such investments had previously been deferred. With approximately 52 million CMNs and written orders generated annually, an electronic system eliminates the time employees must invest in the filing process and reduces the possibility of human error that increases when multiple people are involved in handling paper forms. With e-CMNs in place, home health care providers can reduce the need for frequent follow-ups on paperwork. Lost or misplaced forms are no longer an issue, and providers are working diligently with medical offices to eliminate the time-consuming burden of completing paper CMN forms.

One of the greatest benefits is that payment for services rendered is received in a timelier manner. Statistics show that average filing time for paper forms results in approximately 40 to 80 days (McClinton, 2002). Those using e-CMN technology report that filing time may be reduced to less than a week. This reduced timeframe is a clear financial incentive that offices should look to embrace. Jeffrey Frankel, president and CEO of Trac Medical Solutions, states: "One of the benefits is that e-CMNs will reduce the amount of time to days rather than months to process CMNs, which has a tremendous impact on a supplier's cash flow."

Bob Rice, CEO of eClickMD, adds: "Having an electronic means of communicating with physicians and their staffs can bridge that gap and reduce the turnaround time to less than a week. Physicians are more receptive to the electronic process because it is an organized system and they have the ability to see all the documentation in one place" (McClinton, 2002).

Many doctors already integrate technology into their practices. Research shows that twenty-six percent of physicians are communicating with patients over the Internet, twenty-two percent rely on electronic medical records to store and track information, and eleven percent prescribe drugs electronically (McClinton, 2002). Databases are also widely available for physician use. Given the ease of filing e-CMNs, most doctors and office personnel would be comfortable with the format of retrieving and submitting forms.

Administrative burdens are also reduced with e-CMNs. With paper CMN forms, the labor-intensive completion process increased the rate of errors caused by incorrectly filled-out forms. Remaining in compliance with Medicare is an ongoing concern for medical providers, and rules and regulations constantly change, requiring close attention to "avoid any activity that appears abusive of the system" (McClinton, 2002). Fortunately, e-CMNs can assist with compliance. "Being able to audit or to identify anything that you have stored electronically is so much easier than doing it on paper," states Albert Prast, a Rotech representative and home health care provider. Because it is a truly paperless system, there is a lower chance of losing or misfiling paperwork — a significant advantage when preparing for an audit.