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Medicare Policy to Deny Repayment for Cloned Documentation

According to Medicare policy, cloned documentation generated by template-based EMRs may "lead to denial of services for lack of medical necessity and recoupment of all overpayments made." Due to the structure of template technology, template-based EMR systems "clone documentation" when creating medical records. Medicare’s denial policy states that documentation which is worded exactly the same, or nearly the same, from patient to patient is considered to be “cloned” and does not meet the medical necessity requirement.

When documentation is worded exactly like or similar to previous entries, the documentation is referred to as cloned documentation.

Whether the cloned documentation is handwritten, the result of pre-printed template, or use or Electronic Health Records, cloning of documentation will be considered misrepresentation of the medical necessity requirement for coverage of services. Identification of this type of documentation will lead to denial of services for lack of medical necessity and recoupment of all overpayments made.

It would not be expected that every patient had the same exact problem, symptoms, and required the exact same treatment. Cloned documentation does not meet medical necessity requirements for coverage of services rendered due to the lack of specific, individual information for each unique patient.

Documentation exactly the same from patient to patient is considered cloned and often occurs when services have a specific set of limited or select criteria. Cloned documentation lacks the patient specific information necessary to support services rendered to each individual patient.


At Praxis, we have warned medical practitioners about the inadequacies of this kind of cookie-cutter approach to medicine for years. Template-based EMR systems force you to adapt your style of medicine to pre-set molds and, therefore, interfere with the way you think through a medical case. Their rigidity makes it impossible for the EMR to evolve with you as you learn from experience and as you strive to adjust your practice of medicine to newly published medical findings.

Simply put, templates are counterproductive to the practice of high quality medicine. Now, with this new Medicare denial policy, template-based EMRs will not only lower your standard of care; they will also lower your Medicare payments and risk potential demands for “recoupment of all overpayments made.”

Don’t let this happen to you. Praxis is the only EMR that does not clone documentation. This is because Praxis does not use templates. Instead, it allows you to chart electronically in free text, using your own words, and thereby preserving the unique nature of the medical documentation patient after patient, encounter after encounter.

Bottom Line: Praxis EMR creates a personalized and unique record for every patient. No template-based EMR does that.

Read the Medicare policy on cloned documentation.

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