In CMS' emergency preparedness requirements released last week, the agency outlined requirements for providers to abide by to ensure they would be able to handle complex disaster situations should they arise. The rules require adequate medical record documentation, which CMS says does not mean they have to be electronic.
In previous comments, stakeholders questioned whether medical records had to be documented electronically. They raised many concerns with requiring electronic documentation, including that some providers do not have EMRs, questions about interoperability and concerns that if the power goes down they would be unable to retrieve or copy records.
In response to such questions and concerns, CMS is not requiring EMRs to be part of medical record documentation requirements.
"Medicare- and Medicaid-participating facilities are in varying stages of EHR adoption, and therefore, many would be unable to electronically share relevant patient care information with other treating healthcare facilities during an emergency," according to the final rule. "However, we do expect facilities to be able to provide a means to preserve and protect patient records and ensure they are secure, in order to provide continuity in the patient's care and treatment."
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