A proposed rule to modernize Medicaid managed care regulationslast updated in 2003includes giving incentives for providers not covered under the electronic health records meaningful use program to adopt EHRs and health information exchange.
Medicaid programs through the years have expanded their use of managed care plans. The most recent data from 2011 showed 58 percent of beneficiaries in 39 states and D.C. accessing part or all of their benefits from a capitated health plan, according to the rule, and more adoption of managed care has come since.
But in the age of patient-centered medical homes and accountable care with value-based reimbursement, Medicaid providers who arent on meaningful use-grade EHRs need to better coordinate care and manage populations.
Consequently, the rule proposes that states could make available incentive payments for the use of technology that supports interoperable health information exchange by network providers that were not eligible for EHR incentive payments under the HITECH Act (for example, long-term/post-acute care, behavioral health, and home and community based providers). The state would be permitted to use the health plan payments as a tool to incentivize providers to participate in particular initiatives that operate according to state-established and uniform conditions for participation and eligibility for additional payments.
However, the scope of incentives is not readily apparent in the 653-page rule: The capitation rates to the health plan would reflect an amount for incentive payments to providers meeting performance targets; however the health plans retain control over the amount and frequency of payments.
Nor does the Centers for Medicare and Medicaid Services give much guidance in the way of health information exchange. Providers are referenced to a draft document from the Office of the National Coordinator for HIT that includes a list of best available standards as they implement interoperable health information exchange across the continuum of care.
Yet, the agency does ask for comment on how it can reinforce standards through rulemaking or guidance. For example, as standards become available to electronically integrate long-term services and supports, we could reference them in guidance documents that could then inform contractual requirements for vendors.
The proposed rule is available here.
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