Tag: CCHIT

News from the Front: SATVA, BH-EHR, FTC

Posted on | by SOS Blog | 4 Comments on News from the Front: SATVA, BH-EHR, FTC

Last week, Seth and I attended the semi-annual member meeting of the Software and Technology Vendor Association (SATVA), the behavioral health software and technology trade association to which SOS belongs. At one time, SOS, like many other companies moved along based more on the spoken needs of our customers rather than on long-term projections about what would be required of our industry. Several years ago, we joined SATVA in order to more successfully keep up with information about the mental health software community. I am really glad we did.

In the time since we joined SATVA, the rate of change in the health care marketplace has rapidly accelerated. It is a major challenge for a small company like ours to keep up with all of the information that emerges daily. SATVA is a significant help in that regard. Last year at the late fall meeting, we learned a great deal about certification of behavioral health electronic health record (BH-EHR) programs. This year we discussed the impending release of the draft requirements for that certification and whether it will really be useful for behavioral health organizations.

SATVA has created a section of its web site that is dedicated to keeping a close watch on the certification process. It is a great place for you to get a relatively brief but detailed view of the information related to certification.

We are very proud to be members of SATVA. We are constantly impressed by the individual and collective knowledge of the members of this group and by their willingness to work together in collegial fashion for the well being of the behavioral health community.

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Speaking of certification, the Certification Commission for Health Information Technology (CCHIT), on Friday announced the spring retirement of Dr. Mark Leavitt, the founding chair of the commission. Established initially with federal funding, under Dr. Leavitt’s leadership CCHIT has become a successful not-for-profit organization whose sole purpose is to certify electronic health records (EHR). At the moment, CCHIT is the only certifying body recognized by the US Department of Health and Human Services (HHS).

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And more news about certification…..on Monday, November 16, 2009, CCHIT released the draft requirements for certification of behavioral health software products. This draft is available for public comment until December 11, 2009. If you have curiosity about or input you would like to offer about the certification of behavioral health electronic health record products, now is the time to voice them.

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The Federal Trade Commission (FTC) has again extended the enforcement deadline for the Red Flag rules. At the request of Congress, this has been pushed off until June 1, 2010. The National Council (NCCBH) reported in its Public Policy Update on November 5, that Congress is considering a new bill that would exempt small health care practices from the rules. The FTC had earlier ruled that the rules apply because of the billing practices of many health organizations. Congress is considering exempting practices with 20 or fewer employees. Stay tuned. There is undoubtedly more to come…

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Meaningful Use & Behavioral Health Providers

Posted on | by SOS Blog | 2 Comments on Meaningful Use & Behavioral Health Providers

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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Behavioral Health EHR: Dream or Reality, Obstacle or Asset

Posted on | by SOS Blog | 11 Comments on Behavioral Health EHR: Dream or Reality, Obstacle or Asset

Last month I wrote an article about movement toward Electronic Health Records (EHR) in the behavioral health community. I was stunned by your silence on the issue. So much of my energy for the past two years has been focused on EHRs, their use in general medicine and in mental health, that I was very surprised that our readers were not interested in discussing EHRs. I am not sure whether the booming silence was a reflection of denial about movement toward these products, lack of information about them, or some other factors. So let’s start with some information.

In May, 2003 the President’s New Freedom Commission on Mental Health reported that the mental health community has been much slower to adopt Electronic Medical Records than the general medical community in spite of the potential benefit for consumers being just as great. The Commission concluded that a substantial effort should be made to develop the infrastructure to support interoperable electronic medical records and personal health records, and that the behavioral health community should move forward with adoption of appropriate products.

Early in 2006, a SAMHSA (Substance Abuse and Mental Health Services Administration)-funded Behavioral Health EHR Profile Workgroup, a multi-stakeholder effort to develop an EHR Conformance Profile for behavioral health began work. I joined that workgroup early in 2007 and participated through the adoption of a standard for Behavioral Health EHRs by HL7 this past summer. The Certification Commission for Healthcare Information Technology (CCHIT) has formed the necessary workgroup to develop testing and certification standards for Behavioral Health EHRs and plans to begin such certification by summer 2010.

The thinking about EHRs and their benefit are multiple. Primarily, they are believed to improve the quality of care by minimizing errors and duplication, by providing decision support for the provider, by offering evidence-based practice options, and by making all that information available rapidly to other providers. Adding Personal Health Records (PHRs) into the mix and connecting everything by way of a National Health Information Network (NHIN) or Health Information Exchanges (HIEs) will provide real-time information access for both consumers and providers of health care services.

The election of Barack Obama has spurred lots of discussion about the direction that healthcare reform will take. He mentioned electronic medical records in speeches and debates, but there is not yet much information about how he will pursue policy in that arena. The current financial crisis and recession will undoubtedly take priority over healthcare reform, but the cost of healthcare makes it a pressing issue for everyone.

I have heard providers talk about EHRs in widely varied ways. Some (including some of our customers) have used software products to maintain their clinical records for years and would not want to practice without one. Some clinicians believe that such a product would create obstacles to best care of their clients. Others are concerned about workflow interruption and the amount of time it might take to utilize an EHR. And those of us who work in the industry and are clinicians by training have major concern about privacy and security of health records generally and EHRs in particular.

What are your thoughts about EHRs? Do you see them becoming a part of the picture for your organization? Do you have a plan for purchase of such a product? Do you already use an EHR? How well does it do the job for you? Please let us know your thoughts. What providers think and how they plan to behave will control how this all unfolds.

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Thanks for your thoughts.

E-prescribing and a Behavioral Health EHR: Where to from here?

Posted on | by SOS Blog | 1 Comment on E-prescribing and a Behavioral Health EHR: Where to from here?

For the past several years Synergistic Office Solutions, Inc. has had the privilege and pleasure of participating as a member of the Software and Technology Vendor Association (SATVA), a group of vendors of software and other technology for the Behavioral Health and Social Services community. Last Thursday, I returned from our semi-annual member meeting…charged up with information about what is happening in the behavioral health world and full of questions about how all of the current events will impact SOS and our customers.

Standards for Electronic Health Records (EHR) for Behavioral Health were our primary discussion topic at this meeting. The community mental health world has long known that they will need to use EHRs to maximize the efficiency of their services and document the effectiveness of their treatments. State reporting requirements alone make use of an EHR a worthwhile way to simplify the lives of clinicians and administrators. Psychologists and psychiatrists in the private practice community have been slower to embrace the idea that electronic clinical records will improve care. The cost of the product and the time it takes to learn and use such software has been an obstacle for many organizations. While our mental health clinical record software has been around since 1992, we have many fewer users of that product than of our billing software.

Some states and payers are rapidly moving toward mandates for implementation of aspects of an EHR. FierceHealthIT, a newsletter for those working in information technology for health care, reported last week that MA BCBS will be requiring e-prescribing by January 1, 2011 for physicians who participate in their incentives program. The Centers for Medicare and Medicaid Services (CMS) has developed an electronic prescribing incentive that will increase physician reimbursement by 4.5% by 2014 for those who use qualified electronic prescribing products. The National Governor’s Association (NGA) has provided a forum and support for states to move forward on Health Information Exchange (HIE), electronic prescribing and computerized physician order entry (CPOE) . At the federal level, a public-private partnership has been formed in the AHIC Successor, Inc. to move forward the process of developing a National Health Information Network (NHIN); and the Certification Commission for Healthcare Information Technology (CCHIT) has formed the necessary work group to certify a Behavioral Health EHR.

While the names and acronyms of these bodies may be new to many of you, they are working hard to assure that interoperable EHRs are widely implemented by 2014. Many in the industry consider this an unrealistic goal date for such comprehensive change, but many entities are dedicated to seeing successful adoption of this technology in the not very distant future.

How will the requirement for health care providers to utilize EHRs affect psychologists, psychiatrists and social workers in private practice? Will the expectations be different for private care providers than for behavioral health providers in a community setting? How do you expect these changes to affect your organization? Are you already using an EHR? Let’s talk about where you see this going in your world.