Electronic Submission of Medical Documentation (esMD)

1. Electronic Submission of Medical Documentation (esMD)

2. Agenda • Charter Review • esMD Initiative Priorities • esMD Requirements for the Initiative • Public Participation/Stakeholder Outreach • Workgroup Formation

3. esMD DRAFT Charter

4. esMD Priorities

5. Requirements: Signatures on Medical Record Documents • To support electronic submissions, esMD needs a way to replace wet signatures. • Wet Signatures- The Physician signs in ink to authorize the validity of the document’s content; such as, progress notes and orders. • To be covered by Medicare, most items and services require the signature of a physician in the patient medical record. • Digital Signature must demonstrate that the Provider validated that content within the document is accurate • Use of Digital Signature must ensure authenticity of the provider or organization sending the document to CMS is accurate • In addition, the transaction must when the document was altered and by whom. (i.e. the electronic equivalent of a hand written strikethrough, initials and date) • CMS believes a level 3 digital certificate from a federal bridge CA is the best form of digital signature.

6. Requirements: Provider Name Service • CMS required by law to use NPI number to identify providers. Any providers name service solution must contain a reference to the NPI • To support electronic submissions, esMD needs to leverage Provider Directories to search for providers • To use esMD Phase 2, CMS plans to create a Trading Partner Transaction that a provider would submit through their HIH to CMS. This transaction will require the provider to list their Level 3 Digital Certificate from a Federal Bridge CA. Lesser form of a signature will not meet FISMA requirements. • Determine what data elements CMS should collect when a provider registers for esMD Phase 2 • Determine how CMS should verify the validity of the digital certificates periodically. • Determine the way an HIH should store provider information.

7. Requirements: Structured Content • esMD is currently accepting only Unstructured (pdf) Documentation from providers • CMS wants to expand esMD to accept Structured Content • CMS does not need Summary Documents as they do not meet the coverage requirements • CMS needs the actual orders, progress notes, discharge summaries and potentially every other part of a medical record. • CMS wants to use existing standards; but remember, there must be a field for the digital certificate signature in each standard. Most standards today lack this field. • Existing Standards will be discussed in Walter Suarez’s presentation

8. Public Participation • As an S&I Initiative, esMD is requesting public participation and input to identify and assess existing standards and define requirements • Targeted Participants: • HIHs • HIT/EHR Vendors and Vendor Associations • State HIEs, HIE Vendors • Claims Clearinghouse, HIOs, ROI Vendors • Medicare, Medicaid, and Commercial Payers • Providers, Provider Organizations • SDOs • CAQH CORE • Others with Expertise/Interest in Digital Signatures, Provider Directories, or Claims Attachments

9. Stakeholder Outreach • Which Groups are missing? • How can we reach out to the targeted participants? • Targeted Participants: • HIHs • HIT/EHR Vendors and Vendor Associations • State HIEs, HIE Vendors • Claims Clearinghouse, HIOs, ROI Vendors • Medicare, Medicaid, and Commercial Payers • Providers, Provider Organizations • SDOs • CAQH CORE • Others with Expertise/Interest in Digital Signatures, Provider Directories, or Claims Attachments

10. Workgroup Formation • Potential Workgroups for esMD: • Requirements: • Signatures on Medical Record Documents • Provider Name Service • Structured Content • Policy • Technical