Pathology/Lab Coding Alert

Learn different rules for orders and results.

When physicians order tests from your lab, CMS recently established a clear direction - text messages are not an acceptable way to go, even if the texting platform is secure. On the other hand, labs may be ableto text critical test results to physicians, under certain circumstances.

Read on to make sure you understand the effect of CMS's recent memo on your lab texting policies and procedures.

Use CPOE as First Choice for Orders

In the CMS memo issued Dec. 28, 2017, "CMS clarified that text messaging amongst health care providers 'is permissible if accomplished through a secure platform,'" according to Emily Wein, Alisa Chestler, and Matthew Horton, with the law firm Baker Donelson.

However: That permission doesn't extend to all communications. The memo makes clear that "CMS strictly prohibits the texting of patient orders, regardless of the platform utilized," notes attorney Sumaya Noush with Drinker Biddle & Reath.

Instead: Rather than texting patient orders, "CMS states that its preference is for health care providers to either hand-write an order into the patient's medical record or enter the order via computerized provider order entry (CPOE)," explains attorney Nathan Arden with the law firm Robinson+Cole. "The CPOE should allow for an immediate download into the provider's electronic health record (EHR) system."

In the memo, CMS prioritizes CPOE as "the preferred method of order entry by a provider." This statement aligns with Medicare's EHR incentive program measure, which encourages providers to have more than 30 percent of laboratory orders created by an EP during the EHR reporting period to be recorded using CPOE.

You May Text Results - Maybe

Acknowledging the value of texting, CMS Director David R. Wright, states, "CMS recognizes that the use of texting as a means of communication with other members of the healthcare team has become an essential and valuable means of communication among the team members."

That's good news for your lab if you've already established a system for texting critical lab test results to members of the healthcare team. Such practices can ensure timely reporting and positively impact patient care.

Caution: If you plan to text lab results, you will have to ensure the texting meets some requirements. "All providers must utilize and maintain systems/platforms that are secure, encrypted, and minimize the risks to patient privacy and confidentiality as per HIPAA regulations ...," CMS warns in the memo.

Don't think you can just assess your texting system once and be done. CMS "expects that health care providers and organizations will routinely assess the texting platforms for security and integrity," Arden points out.

Bottom line: The memo shows that "CMS is maintaining a hardline approach with respect to patient orders," Arden says. But CMS also "recognizes the prevalence of texting as an important means of communication among providers."

Resource: To read CMS's memo on texting, visit www.cms.gov/Medicare/Provider-Enrollment-and-Certification/SurveyCertificationGenInfo/Downloads/Survey-and-Cert-Letter-18-10.pdf.