Electronic Certificates of Medical Necessity: A Proposal Medical billing can now become a relatively painless process for the personal in a medical facility through the electronic filing of certificates of medical necessity (e-CMN). Manually filling out paperwork is very time consuming, and is not very cost effective. However, the technological advancements created in the area of medical billing are very efficient. While many offices now fax the CMN's, the incorporation of e-CMN's into the medical office and billing process, decreases overhead costs, reduces paperwork, and helps substantially with the on-going battle to comply with the ever-changing Medicare requirements. While each of the previous reasons is enticing enough to consider incorporating e-CMN's into the office routine, the increase of revenue is certainly a major benefit and is the direct result of the time reduction with the filing process.

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

In September of 2001, the Centers for Medicare and Medicaid Services revised the Medicare Program Integrity Manual (PIM) to include the acceptance of faxed and electronic CMN's 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, while also specifying that they must "adhere to all privacy, security, and electronic signature rules and regulations. Additionally, e-CMNs must contain identical questions/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. However, because it is automated and paperless, the e-CMN is more time efficient and cost effective for a practice since the electronic process allows the staff to concentrate on other vital issues such as patient and office public relations. Most doctor offices are already set up to complete e-CMN's with little additional cost to the overall budget. With simple access to the Internet and the proper computer requirements that doctor offices generally already have, the e-CMN may be filled out, electronically signed, and then submitted to a secure site. After the home health care office receives a doctor's referral, an email will be sent to notify the doctor to access the correct form.

The doctor will simply access the secure e-CMN information via encrypted Internet technology by using a password-protected sign on. This also accesses the doctor's ability to electronically sign the form upon submission. The doctor and staff may rest easy knowing that all current and pending patient privacy and confidential regulations are in compliance. After completion, the e-CMN may be electronically submitted and within a few seconds, the filing process is complete.

Benefits of Incorporating the e-CMN Technology doctor might ask how an e-CMN might be a benefit to their organization. The benefits include increased time, productivity, compliance, and cash flow when a doctor decides to utilize the e-CMN within their office. Since a trusted member of the office staff may complete the e-CMN, the doctor is now freed up from manually signing the forms, thus allowing more time with patients and possibly freeing up more time within a doctor's already short day. More patients may be seen, rounds might be completed sooner, and more vital tasks may be attended to if the doctor is freed up from filing out paperwork.

Accuracy in filing is a big plus. The new HIPAA regulations have created a new wave of concerns, but also opportunities to force providers to change how business is accomplished. This has created a rave of updates and upgrades within many doctor offices where technology purchases have previously been overlooked. With approximately 52 million CMN's and written orders generated annually, an electronic system also eliminates the time employees must invest in the filing process and the possibility for human error that is increased, since more people might be involved in filing the paper form. With the implementation of e-CMN's in a doctor's office, home health care providers may reduce the need for frequent follow-ups to paperwork trails. Lost or misplaced forms are no longer an issue. Home health care providers are working diligently with medical offices to help reduce the time consuming and headache related task related to the procrastination or dread in completing a paper CMN...

Statistics show that average filing time for paper forms result in about 40 to 80 days (McClinton, 2002). Those using the e-CMN technology report that filing time may be reduced to less than a week. This reduced timeframe is certainly a 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 states, "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 utilize technology within their practice. Research (McClinton, 2002) shows that twenty-six percent of physicians are communicating with patients over the Internet. Twenty-two percent of doctors are relying on electronic medical records to store and track information, while eleven percent prescribes drugs electronically. Databases are also available for many uses by physicians. With the ease of filing e-CMN's most doctors or office personnel would be comfortable with the format of retrieving and submitting forms.

Administrative burdens are reduced where e-CMN's are concerned. With the use of paper CMN forms, the labor-intensive task of completion increased the errors created by not completing the CMN correctly. Remaining in compliance with Medicare is an ongoing concern with medical providers. Rules and regulations constantly change and strict attention must be made to the latest rules and regulations to "avoid any activity that appears abusive of the system" (McClinton, 2002). Fortunately, e-CMNs also 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, Rotech representative and home health care provider. However, with the ease of electronic filing, the process is much easier for the doctors and a lot simpler for all providers. Since it is truly a paperless system there is also a lower chance to lose or misfile paperwork. This is certainly a plus when preparing for a visit from auditors.

Cost and Availability

Currently, AAHomecare, eClickMD and Trac Medical Solutions offer e-CMN transmission systems. Each organization provides the technology in an affordable platform. The startup cost is minimal to the doctor's office especially when compared to the increased generated revenue and timelier manner in which e-CMN's may be filed. Rice concurs that the "cost to physicians also will be nominal, which is an important consideration, because convincing them to transition to electronic processing is essential" (McClinton, 2002). Verification for an electronic signature should be obtained and utilized through a password-protected login.

An office should have at least a 200-megahertz PC with the following free software installed:

Internet Explorer 5.5

Adobe Acrobat Reader 5.0

Email account

The home health care provider purchases and installs the software package necessary for the e-CMN filing. The provider simply emails the doctor with the forms ready for completion. Transaction fees range from $1 to $5. Various companies charge between $36 and $50 license fee per location each month with transaction fees will be between $1.80 and $3.00 per transaction. This cost is moderate compared to the man-hours eliminated with the reduction of paperwork. Software subscription packages begin at approximately $370.00 per month for up to five users. Price increases for every five users at a rate of about $200.00. However, after twenty users, prices begin to adjust to per user. For example: For over twenty users, the price of the subscription service is approximately $949.00 per month, plus another $45.00 for each additional user. The price remains constant with increased users over twenty.

Advantages and Disadvantages

Advantages:

The startup cost is minimal compared to the increased generated revenue.

HIPAA compliant.

Increased accuracy and compliance with state and federal regulations such as with the Medicare program.

Ease of use.

E-CMN's are filed in a timelier manner.

Software is being developed that will eventually set "flags" or "alerts" that will require doctors to answer each required question. This will reduce incomplete forms that might otherwise be returned in order to become processed.

Increased office productivity.

Secure digital signatures and may…