Final Rule Falls Short in Promoting Home Health EHRs
The Centers for Medicare and Medicaid Services has released a final rule for the Medicare home health prospective payment system for calendar year 2015 including language on the use of electronic health records by home health agencies.
In the final rule, which will be published in the Nov. 6 Federal Register and can be downloaded here, CMS says that the Department of Health and Human Services will continue to promote the adoption and implementation of certified EHRs but stops short of explicitly stating that HHS encourages their use in the home health setting.
HHS believes all patients, their families, and their healthcare providers should have consistent and timely access to their health information in a standardized format that can be securely exchanged between the patient, providers, and others involved in the patients care, according to the final rule. We believe that HIE and the use of certified EHR technology by HHAs (and other providers ineligible for the Medicare and Medicaid EHR Incentive Programs) can effectively and efficiently help providers improve internal care delivery practices, support management of patient care across the continuum, and enable the reporting of electronically specified clinical quality measures.
Still, the final rule does not go as far as a proposed rule last month on Medicare and Medicaid Conditions of Participation for Home Health Agencies that encouraged home health providers to useand their health IT vendors to developONC-certified HIT/EHR technology to support interoperable health information exchange with physicians, hospitals, other long-term and post- acute care providers, and with their patients. At the same time, the final rule notes that ONC expressed in the 2014 Edition Release 2 final rule an intention to propose future changes to the ONC HIT Certification Program that would permit the certification of health IT for other health care settings, such as long-term and post-acute care and behavioral health settings.
For now, we direct stakeholders to the ONC guidance for EHR technology developers serving providers ineligible for the Medicare and Medicaid EHR Incentive Programs, states the final rule. We encourage stakeholders to also review the Health IT Policy Committee (a Federal Advisory Committee) recommendations for areas in which certification under the ONC HIT Certification Program would help support long-term and post-acute care providers. Further, stakeholders should consider emerging innovative payment models, quality reporting programs, state Medicaid reimbursement for remote monitoring (available in some states) and grants that could provide funding for health IT implementation for home health or incentivize other providers to assist home health providers implementation efforts.
At a May meeting of the HIT Policy Committees certification and adoption workgroup, the Pennsylvania Homecare Association (PHA)which represents more than 500 home health and hospice agenciessubmitted a written comment arguing for establishment of voluntary EHR certification criteria. However, PHA CEO Vicki Hoak asserted that even if these criteria are put in place EHR adoption among home care providers could begin to level off or even decrease because they are not eligible for the monetary and technical assistance provided under the HITECH Act.