I have been avoiding writing about the second draft of the Meaningful Use of Electronic Medical Records (EMRs) definition released by the federal Health IT Policy Committee on July 16. I had been hoping I would hear something that would make me believe the definition would in some significant way benefit our customers. I am disappointed to report that it still appears that the ARRA stimulus funds for adoption of EMRs will be largely unavailable to behavioral health providers, except psychiatrists, unless some change is made through regulation.
Just to clarify my statements above: ARRA provided $19 billion in funding for EMRs. $2 billion will be provided to the states to distribute for grants. Community Behavioral Health Organizations (CBHOs) are included in the eligible organizations for these funds. Unfortunately, it appears that this funding is going to be used by the states where they see fit. I have heard from a representative of at least one children’s psychiatric hospital who was told that funding would be used by the state to build Health IT (HIT) infrastructure and data exchange capability. They were informed that providers could get their funds from the incentives. I will be very curious to see how much (if any) of that $2 billion winds up in the hands of providers of any sort.
The larger part of the funding, $17 billion for Medicare and Medicaid incentives, is designed to encourage providers to purchase EMRs and use them to improve the care of their patients. Of the providers eligible to receive these reimbursements, the only behavioral health providers who are eligible are psychiatrists and certain nurse practitioners. They would purchase a system and then receive reimbursements for some or all of what they have spent depending on a variety of complex formulas. If you are a psychiatrist and you do not see Medicaid or Medicare patients, you are not eligible for funding. If you do treat these populations, you will only be able to get funding from one source, Medicare or Medicaid. The amount of reimbursement you can receive depends upon what proportion of your patients are Medicaid or Medicare recipients, along with other complex criteria.
Senator Jay Rockefeller of West Virginia introduced the Health Information Technology Public Utility Act of 2009 in late April. This bill was intended to assure that certain “safety net” providers like rural clinics and mental health providers could also access funds. That bill has not moved. Unless something happens in regulation, it is not likely that psychologists, social workers, mental health counselors, addiction treatment programs, psychiatric hospitals, or community behavioral health service providers are going to benefit from the stimulus funds to help purchase EMRs.
That said, the Health IT Policy Committee did seem to take into account the input they received from the public about the initial attempt at defining “meaningful use of EMRs”. They have drafted a plan that widens definitions, expands time frames, and provides more opportunities for providers to demonstrate that they are using EMRs meaningfully. Their PowerPoint presentation does a good job of summarizing their points. Details can be found in their updated grid and matrix.
1. The primary goal of the definition is to improve the outcomes of healthcare interventions through data capture and sharing and use of advanced clinical processes. They want providers to focus on health outcomes, not on software. HIT is to be a primary aid to healthcare reform, not use of software for the sake of earning incentive money.
2. It is the intention of the committee that there be a phasing in of meaningful use criteria. The public was concerned that if providers could not meet the 2011 criteria in 2011, they would always be behind the train. The committee now recommends that a provider who does not adopt an EMR until 2012 (or 2015) will start at the 2011 criteria and progress from there.
3. Changing work flows to assure the proper use of IT tools is an essential part of the solution. Trying to use CPOE (computerized physician order entry) can actually cause problems if there are not work flow modifications to make sure the process flows smoothly. An unintended consequence of CPOE in at least one study was diminishing of appropriate care because it was inconvenient to enter the order for the care.
4. Since data-based decision support is the real payoff of using an EMR, the committee wants to see this happen sooner, even it if means implementing only one rule in the decision making process.
5. Since engaging patients in their care is crucial to reduction in costs, providing access to an electronic version of their health record needs to be higher priority and come earlier in the process than previously envisioned.
6. Certification of software should be done by more than one body; CCHIT should not be the sole arbiter of which products should be certified.
While the Health IT Policy Committee has now presented their second draft of the “meaningful use” policy, it has until the end of 2009 to finalize the rules. It appears, however, that the direction is set. If you want to get some of the incentive money to help you buy an EMR, you will need to demonstrate that you can use that EMR and can report a variety of metrics to show how your practice is handling a number of issues. So far, none of those metrics are vaguely related to mental health.
Do you expect your organization/practice to be seeking incentive funding to purchase an EMR? How are you proceeding to assure that outcome? Do you think it is important for behavioral health to be included in the adoption of EMRs?
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