As a requirement of the Health Information Technology for Economic and Clinical Health Act (HITECH Act) of the American Recovery and Reinvestment Act of 2009 (ARRA), the U.S. Department of Health and Human Services (HHS) Assistant Secretary for Planning and Evaluation (ASPE) Office of Disability, Aging and Long-Term Care Policy recently released a study entitled EHR Payment Incentives for Providers Ineligible for Payment Incentives and Other Funding Study. The long-awaited study provided a rationale for identifying provider types not eligible for electronic health record (EHR) incentive payments and identified the provider types who may participate in Medicare and Medicaid but are not eligible for the EHR incentive programs instituted under HITECH.
Home health care and hospice providers – categorized as Long-Term, Post-Acute Care (LTPAC) providers in the report – were included as one of the ineligible provider types that have a frequent need to exchange health information on behalf of their patient populations and would benefit from the use of health IT/EHR technology, including the ability to communicate electronically with other providers.
The ASPE study identified several actions, programs and initiatives that have been leveraged or proposed to provide “direct support” or “indirect support” to ineligible providers for their acquisition and/or use of health IT/EHRs, including: extending the EHR Incentive Programs, grant and loan programs, technical assistance, developing and implementing a health IT infrastructure to support interoperable HIE and more importantly also acknowledges that none of the programs for ineligible providers are sufficient to promote widespread adoption of certified EHR technology (CEHRT).
The study noted that there is a lack of strategic planning or coordination with respect to programs and activities that include a focus on the use of health IT/EHRs by some of the ineligible provider types. Such strategic planning could assist in identifying gaps in current activities to advance the use of EHR technology by ineligible providers and support investments that maximally leverage and are aligned with current policy priorities, and are efficiently targeted.
This study described the importance of having good, reliable and nationally representative data regarding health IT/EHR adoption rates by ineligible providers in order to assesses the need for and effectiveness of investments that seek to advance the acquisition and/or use of health IT/EHRs by ineligible providers. This study also identified several factors that could be considered in estimating EHR adoption rates.
The study also included key considerations for policy makers to help inform them about the complexity of the policy implications for determining incentives and/or other funding opportunities to support the use of EHR technology by ineligible providers. These considerations include the extent to which market forces that have emerged in response to the EHR Incentive Programs and new delivery models such as those encouraged by the Affordable Care Act will drive adoption of interoperable EHR technologies across the health care continuum, including use of such technology by ineligible providers.
The study concluded that many of the health care providers not eligible for the Medicare and Medicaid EHR Incentive Programs, such as LTPAC and Behavioral Health providers, have a frequent need to exchange health information. One of the key benefits of the use of health IT is the ability to exchange information to communicate and coordinate services on behalf of patients, and their physicians and entire care team who are often located in different geographic areas and practice settings.
Advancing the adoption of certified EHR technology solutions by providers not eligible for the EHR Incentive Programs may support the realization of the goals associated with implementing a nationwide health IT infrastructure, new models of care delivery and coordination, and the Medicare and Medicaid EHR Incentive Programs.
The study proposes that filling critical gaps in standards is important to support the interoperable exchange of health information on behalf of vulnerable persons who receive services across the care continuum, including (but not limited to) health care providers who are not eligible for the EHR Incentive Programs. In addition, the specification of standards to support interoperable health information exchange is necessary but may not be sufficient to support the development and implementation of certified EHR technology solutions for these providers. Other actions, programs and initiatives will likely be needed to support and accelerate the use of certified EHR technology by health care providers not eligible for the EHR Incentive Programs.