The HITECH provisions built into last year's American Recovery and Reinvestment Act (ARRA) promise billions in incentives for healthcare providers who would upgrade to electronic health records (EHRs) as part of a long-term strategy to improve healthcare quality and reduce costs. Now, with the implementation of parity for mental health and substance use disorders plus the major reforms promised in the Patient Protection and Affordable Care Act, behavioral health providers and organizations are confronted with a huge agenda for change: more payers, more consumers, more collaboration with other caregivers, and the prospect of full integration with the medical community.
With the help of research into public documents and timely guidance from industry experts-including members of SATVA-Behavioral Healthcare dove into the EHR incentive provisions of the HITECH Act, looking at the implications specific to behavioral health providers.
Where is the EHR money, and when is it available?
The government, through the HITECH provisions of ARRA, is offering financial incentives to eligible professionals (EPs) and hospitals that participate in the Medicare and Medicaid programs. The incentives are intended to help them pay for EHR systems that are needed as a part of ongoing quality improvement and payment reforms.
For hospitals, the HITECH Medicare and Medicaid EHR incentives will become available as early as October 2010. Note that for hospitals, meaningful use reporting requirements and incentive payment years are tied to federal fiscal years, which start October 1 and end on September 30. Thus, hospital incentives under both programs become available in federal fiscal year 2011, which begins on October 1, 2010.
EHR incentives for EPs under both the Medicare and Medicaid EHR incentive programs are tied to calendar years. Incentives for EPs become available in January 2011. (Because states administer Medicaid-funded programs, all states were asked by CMS to submit plans under which they would qualify and administer Medicaid EHR incentive funds. These plans are subject to CMS approval, which could cause some delay in the start dates in some states.)
Are behavioral healthcare professionals and facilities now eligible for this money?
At present, many behavioral health professionals are not yet eligible and most facilities are excluded. Yet, passage of a new bill could change that soon.
Here's what happened: The original ARRA legislation specifically identified physicians and nurse practitioners as eligible professionals, but excluded other licensed behavioral health providers as well as psychiatric hospitals from the definitions of those who would qualify for EHR incentives. A bill to “fix” these disparities, The Health Information Technology Extension for Behavioral Health Services Act of 2010 (HR 5040), was introduced in the U.S. House of Representatives by Congressmen Patrick J. Kennedy and Tim Murphy in April 2010. This bill specifically includes typical behavioral health professionals including clinical psychologists and clinical social workers in the EP definition used for incentives, and specifically includes psychiatric hospitals and behavioral health/addiction treatment centers in its “hospital/organizational” definition.
What's a “certified” EHR system or EHR system upgrade?
To qualify for the initial year of incentives, an EP or hospital must use an EHR that is “ARRA Certified.” The certification means that the EHR incorporates the features required to support current, or Stage 1, “meaningful use” requirements released by the Office of the National Coordinator (ONC). A “temporary” EHR certification rule became effective on June 24, 2010. Temporary certification is intended to fill the gap until organizations who apply to be Authorized Testing and Certification Bodies (ATCBs) are approved to participate in the permanent certification process. According to the ONC, the goal is to have the ATCBs operational in summer 2010 and certifying EHRs sometime in the fall according to Stage 1 (2011) meaningful use requirements. (It is expected that the “temporary” certification program will sunset at the end of 2010.)
In 2013 and 2015, respectively, EHRs certified under the Stage 1 requirements must be recertified in a similar manner to demonstrate that they offer the functionality needed by users to meet Stage 2 (2013) and Stage 3 (2015) meaningful use requirements.
If I buy a certified EHR system or upgrade, will I (or my hospital/organization) meet meaningful use requirements?
No. The idea that “certified” software alone is sufficient to demonstrate meaningful use is a misconception, explains Michael Morris, president of Anasazi Software. “People sometimes think that if they buy a certified EHR, then [meaningful use] is on the vendor. That's not the case. Certification is on the vendor, but meaningful use is on the EP or hospital.” In other words, after the vendor installs the EHR software, users must do the hard work of adapting people and processes to the EHR so that they are meaningfully using the EHR as a part of their routine business activity. That will take planning, process analysis, process redesign, software training, and a lot of adjustment.