Doug Fridsma, M.D., the Office of the National Coordinator for Health IT's Chief Science Officer and Director of the Office of Science and Technology, told a HIMSS14 audience last week that long-term care and behavioral health providers--both of whom are not eligible for the EHR meaningful use incentive programs--are important stakeholders for the interoperable exchange of electronic health information. "We need to expand our portfolio to new use cases that brings them into the community for us to be able to exchange [information] with them," declared Fridsma.

The 2009 HITECH Act provided financial incentives and technical assistance to help eligible providers use certified technology to become meaningful users of EHR. Even though almost a third of Medicare patients discharged from acute-care hospitals must receive treatment from post-acute-care providers, Congress did not include long-term care and behavioral health facilities in the incentive program. In particular patients who receive long-term and post-acute services typically have co-occurring health conditions, such as diabetes or high blood pressure.

A June 2013 Health and Human Services study concluded that "many of the health care providers not eligible for the Medicare and Medicaid EHR Incentive Programs, such as [Long Term and Post-Acute Care] and behavioral health providers, have a frequent need to exchange health information on behalf of their patients, who are among the most vulnerable and costly in our society…advancing the adoption of certified EHR technology solutions by providers not eligible for the EHR Incentive Programs may support the realization of the goals associated with implementing a nationwide health IT infrastructure, new models of care delivery and coordination, and the Medicare and Medicaid EHR Incentive Programs."

The HHS study identified more than 54,000 ineligible provider organizations and 344,000 ineligible professionals who deliver services to 51 million Americans and account for $181 billion, or more than 20 percent of total Medicare and Medicaid expenditures in health care. The study called for exploring opportunities to support EHR adoption among providers that do not qualify for incentives under the Medicare and Medicaid EHR Incentive Programs, including long-term care and behavioral health providers.

To address the problem, ONC in September issued guidance for EHR technology developers serving health care providers ineligible for Medicare and Medicaid EHR incentive payments. The guidance "identifies the 2014 Edition EHR certification criteria from the ONC HIT Certification Program that specifically focus on interoperability to enable electronic health information to be both exchanged and subsequently used by recipients…the capabilities expressed by some of these certification criteria could, if implemented by both eligible and ineligible types of providers, open critical communication lines between eligible and ineligible health care providers in order to support broad health care goals, such as care coordination and reduced hospital readmissions."

At ONC's Annual Meeting in January, Office of Policy and Planning Director Jodi Daniel said that the Policy Committee's Certification Adoption Workgroup is looking broadly at how to leverage the certification program and criteria for ineligible providers, and that long-term care and behavioral health providers have been identified as high priorities. Similarly, Health Reform Coordinator Kelly Cronin said that ONC is trying to get a handle on how to accelerate interoperability and support adoption of health IT by these kinds of providers.

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