The Centers for Medicare and Medicaid Services (CMS) recently expanded the scope of the Health Information for Economic and Clinical Health Act (HITECH) 90/10 funding available to encourage the adoption and promote the use of electronic health record (EHR) technology and health information exchange (HIE). This new funding source provides Medicaid agencies with the ability to accelerate the exchange of information across the continuum of Medicaid providers and gather important clinical and administrative data elements for robust program planning; improvements in quality of care; and managing costs.
This new funding source allows Medicaid agencies to facilitate HIE connections between Medicaid providers even if the provider does not meet the definition of an eligible professional. Activities that are now open for CMS funding include HIE architecture support and on-boarding for Medicaid providers that don’t meet the eligibility criteria for the incentive payments. Initially, CMS limited matching funds to support for HIE for eligible professionals and eligible hospitals. The initial funding opportunity for HIE excluded post-acute providers, substance abuse treatment providers, home health providers, correctional health providers and other health care providers. Medicaid HITECH funds can now support HIE onboarding and systems for all of these Medicaid providers.
Many states have been challenged with developing a truly robust HIE that connects Medicaid providers across all clinicians and healthcare related providers. During the first five years of HITECH, HIT/HIE experienced tremendous growth: many pilot and regional HIEs were developed and became operational, some statewide HIEs were implemented. We know the success stories and we know the challenges that remain to achieve interoperability across the Medicaid provider continuum. The CMS guidance, published on February 29, 2016 – SMD#16-003 (Leap Year Letter) – provides a way for Medicaid agencies to continue to close the gap of providers who can communicate electronically with each other – and importantly, become meaningful users of EHRs.
In order to take advantage of the CMS funding opportunity, it is important to note the requirements for participation.
- Only available for Medicaid agencies to submit the IAPD;
- Time limited – funding only available until 2021, when the HITECH EHR incentive program concludes;
- 90/10% – federal financial participation – states have to provide the 10%;
- Funding is to promote HIE and interoperability – it is NOT for payment for EHRs;
- Funding is for DDI ONLY – it is not for operational costs;
- All providers or systems supported by this funding must connect to Medicaid EPs.
We have learned that CMS seeks innovative and practical solutions to connect Medicaid providers. For example, CMS will fund the following architecture:
- Provider directories
- Secure messaging – with an emphasis on partnering with DirectTrust
- Encounter Alerting
- Care Plan exchange
- Health Information Services Providers (HISP) services
- Query Exchange
- Public Health Systems
As stated earlier, an important aspect of this funding opportunity is the ability for Medicaid agency to use this enhanced funding to on-board Medicaid providers who are not incentive-eligible, this opportunity extends to public health providers, pharmacies and laboratories. On-boarding is defined as the technical and administrative process by which a provider joins an HIE or interoperable system and secure communications are established with appropriate BAA, contracts and consents in place. Therefore, this funding is available to Medicaid to work with the HIE as it connects a Medicaid provider to exchange data and use the HIE services. For example, HITECH funding can be used to cover the reasonable costs – including interfaces and testing. Some of the important use cases:
- On-boarding long term care providers to HIE to access statewide provider directory.
- Rehabilitation providers on-boarded to encounter alerting systems
- Pharmacies may be on-boarded to drug reconciliation systems
- Medicaid social workers may be connected to access care plans
If you would like to learn more about how PCG can help you take advantage of the strategic opportunity CMS has placed squarely with Medicaid agencies, please contact us today: HealthPolicyNews@pcgus.com. Our subject matter experts can help get all of your Medicaid providers connected and sharing important clinical data to manage Medicaid populations more effectively, with higher quality outcomes and improved cost efficiency.
