Two recent developments may significantly impact how rapidly behavioral healthcare providers join the broader push toward the use of interoperable electronic health records (EHRs).
In mid-July the Centers for Medicare & Medicaid Services (CMS) issued the final rule defining what providers have to do to become eligible for financial incentives as “meaningful users” of EHRs (see sidebar). Most healthcare executives expressed relief that CMS has built some flexibility into the definition of meaningful use in Stage 1, reduced some thresholds, and deferred some requirements to Stages 2 and 3. For instance, in the proposed rule, eligible providers would have had to use electronic prescribing for 75 percent of prescriptions. That number has been ratcheted down to 40 percent in Stage 1.
Then at the beginning of August, Sen. Sheldon Whitehouse (D-R.I.) introduced a bill (S. 3709) that would extend eligibility for meaningful use incentives to behavioral and mental health centers, substance use treatment facilities, clinical psychologists, and clinical social workers. A similar bill (H.R. 5040) was introduced in the House in April. (Currently, only psychiatrists and nurse practitioners in the field are considered eligible providers. The incentives could be worth millions to hospitals and individual professionals could earn up to $44,000 under the Medicare incentives or up to $63,750 under the Medicaid incentives.)
Insiders weigh in
Behavioral Healthcare asked providers, industry group representatives, and some software company executives what readers should know about the Stage 1 meaningful use final rule and why the proposed legislation is crucial to boosting adoption levels.
Denise Bertin-Epp, president and chief nursing officer at Brighton Hospital, a 130-bed addiction treatment center in southeastern Michigan, calls herself a huge fan of the meaningful use criteria. “I think behavioral health needs to adopt the same level of sophistication with electronic health records as acute care,” she says. “We can't have it both ways. If addiction is a chronic condition, then we need to endorse the use of information systems that will enhance care for patients and their families.”
Brighton has worked with software vendor MCS on the development of an EHR called Chemical Dependency Health Record (CDHR), which includes CPOE (computerized physician order entry) and eMAR (electronic medication administration record) solutions. “We were using CPOE well before it was identified as a meaningful use goal,” Bertin-Epp says. “We feel we would be in good shape to meet the 2011 and 2012 criteria.”
Although behavioral healthcare organizations themselves aren't currently eligible, their physicians and nurse practitioners can re-assign their incentives to the facility, notes Kevin Scalia, executive vice president for corporate development at software vendor Netsmart Technologies. Under that scenario, a community mental health organization with $20 million in annual revenue might earn $600,000 in incentives as the law stands now, but $2 million to $3 million if the bills in Congress pass. “That's not an insignificant amount either way,” says Scalia, but the legislation is needed to provide a level playing field with acute care.
But some providers say it is unfortunate that part of the behavioral health community may be left out.
Sharon Hicks, chief information officer of Community Care, which delivers behavioral health services to public-sector consumers throughout the Commonwealth of Pennsylvania, says what the Office of the National Coordinator for Health IT has set out to do with meaningful use guidelines makes sense, “but it will be too bad if in the process people who treat the most vulnerable, fragile patients see themselves as disenfranchised.”
If the bills in Congress do not pass and meaningful use is not applicable to community behavioral health centers and psychiatric hospitals, it could be a significant financial hit to the community, Hicks adds. “And if they are adversely affected, I expect people to squawk that it's not OK.”
Unless the legislation becomes law, meaningful use will have limited applicability to a wide range of facilities, says Mohini Venkatesh, director of federal and state policy for the National Council for Community Behavioral Healthcare. Besides encouraging elected officials at the federal level to support the legislation, the National Council also asks providers to pay close attention to what is happening at the state level. “Each state is developing a health IT work plan to submit to CMS,” she says. “These work plans must incorporate behavioral health so that it can be part of state grant opportunities. Otherwise we will see limited adoption.”
Initially, behavioral healthcare providers were left out of the stimulus bill because overall funding was cut back from what was originally envisioned, Venkatesh notes. “But the language of the original bill makes it clear that the use of health IT is seen as reducing medical errors and increasing efficiency across the whole system of care, and that can't exclude certain provider types,” she adds. “I think the software vendors in this space are thinking that way, too, and will get their products certified for meaningful use.”
Highlights of meaningful use Stage 1 rule
CMS’ final rule for the first stage of meaningful use made several modifications to the rule as initially proposed. The changes are widely seen as offering providers more flexibility in their efforts to win incentive payments.
Here are some essentials of the program: