This Year (and Next!) in Behavioral Health

A recent article by Dennis Grantham really highlights the developments in health reform we’ve seen in 2012. Most importantly, the Supreme Court decided to uphold the constitutionality of the insurance mandate in the Affordable Care Act (ACA) and the Medicaid Expansion as well.

Numerous regulations around ACA-promised reforms, like ending discrimination based on pre-existing or chronic conditions, have already been implemented. Additionally, ACA-mandated mental health and addiction treatment benefits, though they will vary state by state, should be in place for nearly all Americans by 2014.

This is all evidence that it’s been a pretty good year for our industry. However, we still have to see how the ‘fiscal cliff’ situation plays out. If we go over the ‘cliff’ – meaning a deal between Democrats and Republicans isn’t made – we will likely face significant cuts to Medicare and likely Medicaid in addition to other social safety net cuts This is because as Washington looks for money to reduce the deficit, taking money out of the Medicaid budget is often floated as a method of accomplishing this.

Another development that needs to occur in order to better level the playing field with primary care is some sort of behavioral health information technology act, which would expand Meaningful Use eligibility to behavioral health hospitals, psychologists and licensed therapists. There have been a number of these bills proposed over the last few years, though none have made it out of the committee stage. Currently, the Behavioral Health Information Technology Act of 2012, sponsored by Tim Murphy of Pennsylvania, has been referred to Committee as of June 27, but there has been no further progress since then. Though it’s unlikely that new spending will get passed, the recurrence of these bills in Congress is significant as it demonstrates that the issue is still relevant to our community and one we are passionate about.

What changes do you see as important as we head into 2013?

How Stage 2 Applies to You!

As you may have heard last week, the federal government released the final rule for Stage 2 of its Meaningful Use program. The rule – effective for those participating in 2014 (or potentially later), has already had the opportunity to be commented on by the public, and according to Farzad Mostashari, will encourage ‘maximum flexibility’ while setting standards around interoperability.

Two key highlights include:

• Reassurance that no providers will be required to follow Stage 2 requirements before 2014 (ensuring you have time to get your EHR in order!).
• Going along with that, it allows current “2011 Edition Certified EHR Technology” to be used until 2014. It also further outlines the certification criteria for the certification of EHR technology, so agencies can ensure their systems qualify them for incentive payments.

Both of these points are great for the human services industry. This allows providers some time to adopt and ensure they are meaningfully using their Stage 1 certified EHRs. This enables them to focus on reporting on outcomes and data-driven care by relying on the data they are now collecting, which makes attesting to Stage 2 (which places a greater focus on Health Information Exchange) a few years from now significantly easier.

You can find a CMS fact sheet on the final rule here. Additionally, if you’d like to read the rule in its entirety (and have the time on your hands to wade through 650 pages), you can access that here.

Guest Article – Breaking Down Barriers to Health IT

Hello everyone! Today we are featuring our very first guest article, and I’m looking forward to reading all of your comments!

Today’s piece is written by Janice Stewart, who is the Vice President of Information Technology at Northeast Parent & Child Society, a large child and family services and behavioral health agency in New York State.

Breaking Down Barriers to Health IT

In June 2012, the National Council for Community Behavioral Health Care published a report on HIT Adoption and Readiness for Meaningful Use in Community Behavioral Health. Of their more than 2000 surveyed members, only 21% of respondents are using EHRs with no more than 2% ready to meet Meaningful Use requirements by the end of this year.

The report presents many key findings regarding the barriers behavioral health organizations (BHOs) will have to overcome to implement health IT and achieve Meaningful Use, with 30% of responding organizations identifying “upfront financial cost” as the leading roadblock to implementation. Among the many other barriers, approximately 9% of surveyed agencies cited “workforce issues” as significant – specifically, the lack of dedicated staff to properly select and implement technology, manage the project and maintain the systems.

For many community BHOs, funding constraints relegate the development of an advanced technology program to the status of a luxury, and they manage to get by with a minimum of resources, including an IT workforce.  That “minimum resource” approach will need to change with HIT and EHR adoption, regardless of the size of the organization. BHOs have traditionally utilized technology as information collection systems created to alleviate manual tasks and accumulate data for administrative, financial, and compliance purposes, or because an external regulatory body requires it. However The EHR is not there to simply collect data – first and foremost, the EHR is a tool for the behavioral health worker to undertake clinical practice, with the ultimate goals being interoperability and information exchange to improve quality care coordination. The strategic goals of HIT are based on data derived from the real time activities of end users – clinicians and practitioners – whose primary objective is to facilitate behavioral health care.

Consequently the clinician’s faith in the new tools is critical to strategic success. The National Council’s report finds that 7% of agencies see “provider resistance” as a barrier. Informed technical support will be essential as providers experience a complete shift in conventions of practice, adjusting to changes in how they treat, how they document, and to some extent the very language they use as organizations standardize data elements during EHR implementation. Equally, building and supporting the EHR workflow requires not only technical skills, but strong business analysis capabilities to coordinate the cerebral process model of behavioral health treatment with a logic-based information technology model. It’s meshing the two approaches that creates success in the form of worker acceptance and satisfaction, which are mission critical to successful HIT adoption.

Regardless of the size of the organization or whether the system is hosted in the cloud, the implementation, management and support of HIT and HIE does require dedicated staff with more than just technical skill sets. HIT requires a continuum of true integrators who can:

• support the clinical workforce toward the organizational goal of integrated healthcare
• understand current and emerging technology, security and privacy, and
• respond to clinical advances, regulatory changes and integrated healthcare strategy.

As part of their overall plan, the Office of the National Coordinator for Health Information Technology (ONC) has funded the Health IT Workforce Development Program to train a new workforce of Health IT professionals. With a shortage predicted as overall adoption increases, BHOs will be competing for adequate resources.

Organizations such as the National Council are strongly advocating to create awareness, and to affect needed change to the eligibility rules that are hindering Community BHOs from adopting HIT because of major upfront financial barriers. Their June report stimulates awareness of many other hindering factors as well, such as critical workforce and acceptance issues.

As Behavioral Health Organizations prepare for HIT, they must recognize that with its adoption, technology becomes fundamental to practice. Therefore they must adequately plan for and fund the talented internal and/or consultative workforce resources that are a key requirement of success.

Stage 2 Meaningful Use and Integration: Learning to Speak the Same Language

More and more, providers and industry analysts are discussing Stage 2 of the Meaningful Use incentive program, which is scheduled to begin in fiscal year 2014. You can find the proposed rule here if you would like to learn more.

This article published last month in Healthcare IT News outlines the best case scenario for Stage 2 Meaningful Use. Whereas Stage 1 is focused on capturing data electronically, Stage 2 places a greater emphasis integrating EHR systems together so they can share data. One of the key issues in data sharing, however, is that while systems may be able to communicate, it won’t matter if they aren’t speaking the same language!

This is touched upon in the free whitepaper The Other Side of the Continuum: Why the Rush to Modernize Leaves Human Services Behind, which outlines how each funder (a state Medicaid agency, for instance) of human services agencies can require different forms and different data formats. One may ask that hair color be recorded as “blonde, brunette, etc.” while another may require “brown, red, yellow, etc.” These small but significant differences hinder communication between EHR systems in different states, as there may not always be a 1-1 conversion of data. Are brown eyes the same as hazel eyes? Some agencies may not distinguish while others might. And these differences become more complex depending on the type of health or demographic information, since hair and eyes are just the tip of the data iceberg.

This will hopefully become more clear as providers move toward ICD-10 and better map their industry-specific terminologies toward a unified standard.

National Council’s Hill Day Outcome – New Legislation!

A few days before the Supreme Court upheld the Patient Protection and Affordable Care Act, around 600 people attended the National Council’s 2012 Public Policy Institute and Hill Day, an event consisting of sessions and workshops on federal behavioral health policy, followed by visits to lawmakers to advocate for the priorities of the behavioral and mental health fields.

A recently introduced bill was certainly influenced by Hill Day, and that is the Behavioral Health Information Technology Act (H.R. 6043). Much like its counterpart in the Senate (S.539), this bill will add community mental health centers, psychiatric hospitals, residential and outpatient mental health treatment facilities and substance abuse treatment facilities to the list of organizations eligible for federal incentive payments.

Currently, you can receive incentive payments for the adoption of health information technology if you have a psychiatrist or nurse practitioner on staff, but both bills would extend incentive payments for electronic health records to certain types of behavioral health organizations that are not currently eligible.

This bill had expired in a previous session of Congress, so hopefully it will gain more traction this time around!

Do Incentive Dollars Drive EHR Adoption?

A recent survey indicates that 95% of physicians are adopting EHRs in order to achieve Meaningful Use, whereas only 53% are doing so to improve patient quality of care, making that a distant second. Indeed, another study reported that those hospitals who are ineligible for Meaningful Use incentive payments have a ‘dismally low’ EHR adoption rate. As an article in FierceEMR suggests, this shows that, perhaps unsurprisingly,  the availability of Meaningful Use incentive funding plays an important role in EHR adoption.

This may contribute to why it seems the human services industry is not as driven to adopt and Meaningfully Use EHR systems – many do not employ the eligible professionals required to earn incentive funding.

Under the current rules, licensed therapists, psychologists, and behavioral health clinics are all currently ineligible for funding. Hopefully with the delay of Stage 2, ONC will take advantage of this additional time to reevaluate its eligibility requirements.

For more information on the subject of healthcare reform within the human services industry, I urge you to check out the whitepaper, The Other Side of the Continuum: Why the Rush to Modernize Leaves Human Services Behind.

Health Information Exchange in 2012

In a recent post on ONC’s official blog, Dr. Farzad Mostashari, National Coordinator for Health Information Technology, discusses Stage 2 of the Meaningful Use program, and restates the importance of Health Information  Exchange (HIE). He believes that the HIE program will see a lot of progress this year, citing the fact that:

–          Over 70% of hospitals are planning to build infrastructure supporting HIE

–          EHR adoption doubled between 2008 and 2011.

–          Grants are being provided from ONC’s State Health Information Exchange Program

While his post is geared more toward primary care, it is also relevant for human services providers as well. The increased emphasis on HIE and interoperability means that more primary care providers will be talking about accountable care organizations and other payment and service delivery models that benefit from the inclusion of human services agencies.

However, since human services agencies don’t often qualify for Meaningful Use funding, as many may not employ eligible professionals, these providers will likely encounter more financial hurdles than primary care in the adoption, implementation and meaningful use of EHR systems. Hopefully over the coming year ONC will see how this could complicate the development of true, nationwide HIE and coordinated care.

Why it’s Time to Standardize Electronic Data Interchange (EDI)

As a complementary piece to her recently released whitepaper, Fran Loshin-Turso has recently authored an editorial piece for Behavioral Healthcare magazine entitled, “Making EDI Standardization a Priority in 2012.” The piece touches on many of the points of the whitepaper while concisely explaining what Electronic Data Interchange (EDI) is, how it affects your provider organization, and why many funders don’t currently support it.

The piece ultimately offers three recommendations to remedy the situation:

• Government payers should stop spending taxpayer dollars developing systems that require providers to perform duplicate data entry.
• Payers must develop standard reporting formats either built on an existing standard, like the CCD, or another standard.
• The Office of the National Coordinator for Health Information Technology (ONC) should broaden the scope of the Meaningful Use Program to encompass all Health and Human Services Information Technology.

If you are looking for a brief overview on this complex issue, click here to read the whole article.

Healthcare Associations Weigh in on Stage 2 Meaningful Use

Last week, several groups have come out with their comments on the Stage 2 Meaningful Use proposed rule (click here for full text), which was distributed last Thursday by the Department of Health and Human Services (HHS).

Among some of the responses:

• Health IT Now, a group of 62 patient, provider, employer and payer organizations that support the rapid adoption and use of heath information technology, thinks the proposal does not go far enough given that the rule delays the implementation of Stage 2 standards for those who adopted EHRs in 2011. The group points out that the industry ‘loses a year of interoperability’ as in 2012 and 2013, clinical information exchange is not something that is even tested under the proposed rule.
• The chair-elect of the Medical Association Board has stated that HSS should better evaluate the results of Stage 1 before finalizing Stage 2, as having that information would better inform their decision-making in the process.
• The Healthcare Information and Management Systems Society (HIMSS) stated it was pleased with the recommendations, interpreting that the delayed standards that Health IT Now criticized will give providers enough time to meet them.

There is likely to be more industry feedback in the coming weeks as more groups sift through the 455-page document, so it will be interesting to see how the proposed rules hold up under greater scrutiny.

Introduction to Medicare EHR Incentive Program for Eligible Professionals

The Centers for Medicare & Medicaid Services (CMS) recently created a new resource for Eligible Professionals – a guide that outlines the Medicare EHR incentive program. This includes how it differs from the Medicaid incentive program, the requirements they need to meet to achieve Meaningful Use, what steps they need to take to attest, and how long it is estimated to take to receive incentive payments.

If you aren’t sure which incentive program to apply for or are simply looking for a lot of Meaningful Use information in one place, you should definitely take the time to read the full guide.