Clinical Documentation and the Private-Public Care Coordination

CMS has announced that it has selected 500 primary care practices in seven regions to participate in a program to strengthen coordinated care in a partnership between payers from CMS, state Medicaid agencies, commercial Health Plans, self-insured business and primary care providers.

Under this initiative CMS will pay primary care practices a care management fee that will average $20.00 per month per each Medicare fee-for-service enrollee. Commercial, State, self-insured etc. will also offer enhanced payment to primary care practices to support coordinated services and the delivery of high quality care according to EMS officials.

On the face of it sounds great but there are realities for the physicians who want to participate. First the reimbursement hardly provides the kind of incentive that will pay for the time it will take to implement this program from practice to practice. The second item is that the only proof of “Coordination of Care” is in the clinical documentation. The documentation must reflect the reality of the interactions among the disciplines involved in the care of the patient. Very often in reviewing records, one finds lots of care but poor coordination. Of course the goal is absolutely needed. However the medical philosophical outlook has to change and the minimal incentive to change it is very little.

The goal for the Primary Care physician practice management is to coordinate care with other providers, engage patients in managing their own care, and provide individualized care for patients with multiple chronic conditions according to CMS. Many years ago CMS proposed a new set of rules for clinical documentation that propose “integrated documentation reflecting Integrated and coordinated care. That was in the 90’s and was withdrawn as a final rule.

The Coordination of care of and the supporting clinical documentation improvement are worthwhile goals and there are Primary Care folks doing it. However for the vast majority it will be difficult and the incentive will not be enough to have physicians move forward. In the private practice of medicine we are seeing a trend toward Coordination of Care and exceptionally good documentation. This program (not a program) is known as Concierge Medicine. In this scenario the physician sees few patients but is reimbursed at a higher rate by the patients. This is slowly becoming a movement for those who are barely making a living in the current reimbursement environment.

Clinical Documentation and the Private-Public Care Coordination