EHRs embedded in payment rules for non-MU providers

Electronic health records continue to become a fixture in the healthcare industry, even in payment rules affecting providers that don't participate in the Meaningful Use program.  

The Centers for Medicare & Medicaid Services' final 2015 payment rule for inpatient psychiatric facilities (IPFs), published this week, adds the use of an EHR measure for the fiscal year 2016 payment determination and subsequent years, even though IPFs are not part of the Meaningful Use program and do not qualify to receive incentive payments.

"We believe that the use of certified EHRs by IPFs [and other providers ineligible for the Medicare and Medicaid EHR Incentive Programs] can effectively and efficiently help providers improve internal care delivery practices, support the exchange of important information across care partners and during transitions of care, and could enable the reporting of electronically specified clinical quality measures [eCQMs]," the rule states.

CMS did not go that far in several of its other 2015 payment rules but did include references to EHRs and provide a glimpse of where the agency may be heading in the future.

In its 2015 prospective payment rule for skilled nursing facilities, published in the Federal Register on Aug. 5, CMS reiterates its intention to accelerate health IT and health information exchange. It would do that through a number of initiatives, such as aligning incentives and payment adjustments to encourage provider adoption and optimization of HIE technology and services; adoption of certification requirements for interoperability; support for privacy and security of electronic patient infuriation; and governance of health infuriation networks.

The final rule reports that commenters on the proposed rule, which floated these ideas, were widely endorsed.

CMS floats similar concepts in its final 2015 payment rule for inpatient rehabilitation hospitals, including the feasibility of requiring electronic CQMs. Commenters expressed concerns regarding the lack of incentive funding and integration of IRFs in EHR standards and HIE development. CMS thanks commenters for their input but doesn't provide much insight as to what the agency will do in the future.  

EHR adoption has been less popular among provider groups that are ineligible for the Meaningful Use incentive program, such as behavioral and long-term care providers. This dichotomy could prove to be problematic as the Meaningful Use program requires participants to share data along a continuum of care.

To learn more:
- here's the SNF rule
- here's the IPF rule (.pdf)
- read the IRF rule (.pdf)

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