A federal regulator doesn't just want greater interoperability in hospitals and doctors' offices. The Centers for Medicare and Medicaid Services is also pushing for increased interoperability in facilities that patients are transferred to after their hospital stay.
Earlier this month, CMS issued a request for information (RFI) from industry players on how to incentivize EHR adoption in post-acute care settings, such as skilled nursing facilities, as well as how to improve and measure interoperability among post-acute facilities.
This isn't the federal regulator's only push toward interoperability this year. In February, CMS released proposals for highly anticipated interoperability rules that aim to improve health data exchange and increase patient data access. This most recent RFI gives healthcare professionals a better idea of what CMS is really after: interoperability across the entire patient care spectrum.
Post-acute care left out of EHR incentives
The RFI asks members of the healthcare industry to provide input on how the U.S. Department of Health and Human Services (HHS) can more broadly incentivize EHR adoption in post-acute care settings. It also asks for comments on potential policy strategies HHS could adopt that would enable the federal organization to provide financial support to post-acute care setting providers for EHR adoption.
The CMS RFI states that many post-acute care settings, as well as behavioral health and home and community-based service providers, have been slower than acute care hospitals to adopt EHRs for a significant reason: They can't participate in the Medicare and Medicaid EHR Incentive Programs, now known as the Promoting Interoperability Programs. The program provides reimbursement for EHR adoption.
Jeffery Smith, vice president of public policy at the American Medical Informatics Association, said post-acute care and similar settings were left out of the American Recovery and Reinvestment Act of 2009, a stimulus bill that designated what care settings could receive reimbursement for EHR adoption. CMS is unable to provide financial incentives that would encourage post-acute care settings to adopt EHRs under the current law, he said.
"There have been several attempts over the years within Congress to pass additional legislation that would make available funds for [post-acute care settings] and behavioral health, but those efforts have never crossed the finish line, mostly because it would cost additional dollars," Smith said.
CMS seeks input on measuring interoperability, standardized data
Smith said, on top of seeking feedback for incentivizing post-acute care settings to adopt EHRs, CMS also wants to know how to measure interoperability in those settings once EHR adoption occurs.
Jeff SmithVice president of public policy, American Medical Informatics Association
The CMS RFI notes that data documenting EHR adoption by post-acute care facilities is limited. For post-acute care facilities that have adopted EHRs, data sharing is still a low priority, because vendors have been slow to include interoperable functions in their products, according to the CMS RFI. According to a national survey of skilled nursing facilities cited in the RFI, 64% of skilled nursing facilities used an EHR in 2016, but only 7% could receive, send, find and integrate patient health information.
"Expanding the scope of interoperability measurement beyond settings that were eligible for the EHR Incentive Programs is critical as efforts are being made to enable health IT and exchange capabilities across a broader range of care settings," the RFI stated.
Smith said policymakers have looked for additional ways to encourage EHR adoption in post-acute care settings beyond cash incentives, including through the IMPACT Act, which requires Medicare post-acute care facilities to report standardized quality measures and assessment data in order to be reimbursed.
CMS wants input on whether hospitals and other acute care settings should be required to collect and share some of the same post-acute care standardized data elements in their EHRs through the expansion of the U.S. Core Data for Interoperability process, a standardized set of data classes that are required to facilitate interoperable health information exchange.
Greater EHR adoption doesn't mean greater interoperability
Even with greater EHR adoption, Smith said the healthcare community -- including post-acute care settings -- faces a long road ahead.
"Even if we were dealing with a much higher percentage of adoption of EHRs, we're still dealing with fundamental interoperability issues, which is why CMS is asking, 'How do we measure interoperability?'" Smith said. "And we're still dealing with the lack of standardization when it comes to exchanging, creating and using these kinds of data elements."
Industry players have until early April to submit feedback to CMS.