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information, unless an exemption or exception applies. Although the information blocking rules currently apply only to the data elements represented in the United States Core Data for Interoperability (USCDI Version 1), the rules will extend to all electronic health information beginning October 2022.
• Changes to Board of Medicine administrative rules effective April 26, 2021 addressing services rendered via telehealth, delegating the prescribing of controlled substances to Advanced Practice Registered Nurses, and continuing education requirements for controlled substance prescribing.
• As part of the 2019 Michigan Auto No-Fault Reform Act, new caps on fees which may be charged for services rendered to individuals injured in an auto accident take effect beginning July 2, 2021.
• New Public Health Code administrative rules which modify the license renewal expiration date for various health professions, including physicians, which beginning December 22, 2020, must be renewed 3 years on or before the “Issue date.” In addition, beginning June 1, 2022, applicants for initial or renewal of licensure or registration of health professions other than veterinarians must complete, in addition to all other continuing education requirements,
implicit bias training which complies with the requirements set forth in the new rules.
3. Are my medical documentation practices compliant?
Michigan law generally requires physicians and other health care providers to keep and maintain a record for each patient for whom he or she has provided medical services, including a full and complete record of tests and examinations performed, observations made, and treatments provided. Third party payors also impose various documentation requirements to support payment of claims submitted for services rendered by providers, such as medical necessity.
Although the administrative burden of medical documentation can be onerous at times, physicians who use electronic medical record systems (EMR) to document services rendered should use caution when using various features provided by the EMR to streamline medical documentation, such as check boxes, templates and other auto-fill-in options which allow for information to be replicated from patient to patient or from visit to visit. Physicians who over-rely on these time-saving functions may risk challenges to the integrity of their medical records. For example, a third-party payor may reject claims during a post- payment audit on the basis that the medical record does not support that applicable coverage and
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JUNE/JULY 2021 | WWW.OCMS-MI.ORG