D'Arcy Gue

CMS To Fund “Wiring” of Outlier Providers? Read the Fine Print.

March 10, 2016

Healthcare Industry 4 Minute Read

CMS made a center stage announcement at last week’s Las Vegas HIMSS conference that it is expanding financial help to a broader base of providers to purchase interoperable technology. This seemed like great news, especially to behavioral health,  substance abuse and long term care facilities. The announcement went viral at the conference. Alas, the proverbial devil is in the details.

Andy Slavitt, CMS’ Acting Administrator,  announced that states can now receive 90 percent matching funds to pay for technologies “to help bridge an information sharing gap in Medicaid … to connect a broader variety of Medicaid providers.” The new variety of providers includes long term care, behavioral health, addiction treatment, home health and others that have been ineligible for any technology financial support including Meaningful Use / MIPS incentives.

For many, the news suggested that these “outlier” providers would finally get financial help in purchasing an EHR. After all, what does support for interoperability mean if you don’t have an EHR to share information with other providers? You get help with buying an EHR, right? No, you do not. Let’s read the fine print.

The focus of CMS’ enhanced funding initiative is on helping MU eligible providers (EPs) achieve health information exchange with non-eligible providers. It is not on helping non-eligible providers to develop or broaden their “wiredness” unless they already have an EHR. Medicaid’s Data and Systems Group and the ONC Office of Policy have partnered to more aggressively support eligible Medicaid providers in coordinating care with non-eligible providers and in attesting to Meaningful Use / MIPS Stages 2 and 3.

HHS representatives spelled out the details succinctly in a presentation at the HIMSS conference;:

  • The funding is for HIE and interoperability only, not to provide EHRs.
  • The funding is for implementation only; it is not for operational costs.
  • The funding still must be cost allocated if other entities than the state Medicaid agency benefit.
  • All providers or systems supported by this funding must connect to Medicaid EP (eligible providers).
  • The major distinction from previous permitted funding options, is that Medicaid
    HITECH funds can be used for more than interfaces for EPs. Now it can be used for the public health infrastructure more broadly to allow EPs to meet Meaningful Use / MIPS.

The speakers suggested that the enhanced funding will enable state Medicaid agencies to on-board Medicaid providers that are not MU incentives eligible, e.g. behavioral health organizations, into HIEs. Examples included on-boarding them to statewide provider directories, encounter alerting systems, drug reconciliations systems and query exchanges.

Unfortunately, press statements didn’t discuss these significant funding limits. Instead, according to Slavitt: “We’re announcing funding to connect many of the remaining parts of the system that are not part of the EHR incentive programs but serve our neediest patients every day….Finally, we are going to wire up long-term care, behavioral health and substance abuse providers.” He noted that CMS sees many benefits to the initiative, from care coordination to medication reconciliation to public health reporting.

This sounds great.

But, how can a paper-based behavioral health hospital be “wired up” to a drug reconciliation or encounter alerting system? Hmmm…a FAX or telephone comes to mind; they have wires, don’t they?

Most estimates indicate that as many as 50 to 80 percent of behavioral health and substance abuse facilities do not yet have EHRs.  Contrast this with the fact that 98 percent of eligible hospitals and nearly 60 percent of office-based physicians had implemented an EHR by the end of 2015, and received over $32 billion in tax dollars to cover costs.

In fact, HHS is well aware of and apparently concerned about this disparity and its implications to interoperability.  In its Fiscal Year 2017 budget submission to Congress in late February, HHS proposed adding (legislatively) certain behavioral health providers to the EHR Incentive Programs, explaining that “The expansion is meant to facilitate the integration of behavioral health and medical care, and promote the sharing of clinical data needed to provide better patient-centered care.” This proposal came on the heels of a bill introduced in 2015 by Reps. Tim Murphy and Eddie Bernice Johnson that would include behavioral health and addiction treatment providers in EHR Incentive Programs.

Both initiatives are good news. But not good enough yet to substantively move behavioral health, substance abuse, long term health and many provider outliers into the increasingly wired mainstream of healthcare. This continues to be the realm of acute care providers — mainly because they received a paid invitation. The resulting hole in patient continuum of care still defines CMS’ “information sharing gap.”

As long as this gap remains, nation-wide systems interoperability,  the potential for a complete continuum of care, and increasingly needed population health management will remain elusive.

I urge you to review the HHS presentation for the details of its new funding initiative.