Health Information Exchange (HIE) and the Medicaid EHR Incentive - - PowerPoint PPT Presentation

Health Information Exchange (HIE) and the Medicaid EHR Incentive Program

Liz LeBreton Health IT Coordinator

Purpose of this Presentation

• 1. Why talk about Health Information Exchange

(HIE)?

• 2. Health Insurance Exchange (HIX) in the HIE

Space

• 3. Provide overview of State Medicaid Director

(SMD) letter on use of Federal financial participation (FFP) for HIE as part of the Medicaid EHR Incentive Program

• 4. Funding for State Health Information

Technology (HIT) Coordinators

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EHR Incentive Programs

ICD-10 5010

PQRS e-reporting

IQR e-reporting

ACA Operating Rules and Standards

HIE

ACOs

PCMHs

SNOMED LOINC

CCDA

Interoperabilty

4

The country’s e-health future is dependent on the sharing of healthcare data among stakeholders that comprise a national health information infrastructure Overwhelming majority of Americans receive their care from more than one caregiver or provider

eHealth Transformation as Standardization

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Standardizing health data Deploying an industry model with standardized metadata Increasing the level of standardization and incenting stakeholders to make exchanging healthcare data easier across organizations

Policy & Program Levers

6

Administrative Simplification, including ICD-10 Medicare and Medicaid EHR Incentive Programs Quality Data, Quality Measures Health Information Exchange

“Administrative Simplification” & ICD-10

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Administrative Simplification:

» Standardized operating rules » Standardized benefit coverage information » Standardized benefit utilization information » Standardized timeliness of query response » Standardized referrals and pre-authorizations

ICD-10 will improve:

» Reimbursement » Research » Quality measurement » Public health » Organizational monitoring and performance

EHR Meaningful Use (MU) & Interoperability

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Stage 1

(began in 2011; starting point for all providers)

Focus: transferring data to EHRs and being able to share information

Stage 2

(to be implemented in 2014 under the final rule)

Focus: online access for patients to their health information and electronic health information exchange between providers

Stage 3

(expected in 2016)

Focus: demonstrating that quality of health care has been improved

EHR Meaningful Use & Interoperability

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Standardization through Stages

Stage 1

Standardized Data

• Problem list
• Medication list
• Etc

Stage 2

Standardized Data Exchange

• Consolidated

Clinical Document Architecture (CCDA)

• DIRECT

More Data

Stage 3

???

Quality

• Goals

– Better Care – Healthy People/Healthy Communities – Affordable Care

• Nexus: Quality Data / Health Information

Exchange / EHRs / E-Health Standards

• From paying for volume to quality and

value-based payments

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Health Information Exchange

• Evolving nature of HIEs from exchanging

data and incenting EHR meaningful use to turning data into actionable information

• HIEs emerge in the healthcare marketplace

as competing platforms of differentiated healthcare data services

– Provide integration of data activities – Offer enterprise decision and business intelligence

(BI) support tools

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Why is Health Information Exchange Important?

• Stage 1 of meaningful use includes several

measures that are related to the electronic exchange of health information

• Stage 2 increased the use of electronic

exchange of health information

• HIE is also integral to the success of delivery

system reforms

• CMS believes that States have a role in

promoting EHR adoption and HIE

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Medicaid Enterprise Transformation Using HIE

• HIE, while having an obvious role in meaningful

use, also can transform other aspects of the Medicaid Program

– Reporting to public health – Detecting fraud, waste and abuse – Facilitating the submission of clinical quality measures

(Children’s Health Insurance Program Reauthorization Act (CHIPRA), Affordable Care Act (ACA), etc)

– Data aggregation, analysis, etc. – Enabling better patient engagement and self-

management through HIE-supported patient portals

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The Connection Points

03/27/2013 14

Electronic Health Records Health Information Exchange Health Insurance Marketplaces Eligibility, Enrollment and Claims Processing Systems

• Consumers
• Providers
• Vendors
• Consumers
• Providers
• Payers
• Vendors
• Consumers
• Payers/Issuers
• Vendors
• Consumers
• Providers
• Payers
• Vendors

Why Look at Commonalities?

A coordinated vision and enterprise perspective

• n the IT build contributes to:

– Lower incremental costs – Leveraging both state and federal funding – Maximizing staff resources – Creates a consistent approach for governance so

changes can be managed more globally

Is it too late? No! Not for HIE/HIX/Medicaid Management Information System (MMIS)/Eligibility & Enrollment (E&E) integration

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Leveraging IT for both HIE and HIX: possible shared services

Identity Management

– Provider directory – Person Record Locator Service – Enterprise Master Patient Index (eMPI) – Identity Proofing

Master Data Management Enterprise Data Stores Address Validation Enterprise-level “case” management for look up/query

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States are building incrementally. HIEs are building

• incrementally. MMIS and E&E are being transformed.

Do a gap analysis for your 2015 vision!

Guidance Overview

• American Recovery & Reinvestment Act – February

2009

• SMD Letter: Planning Guidance – September 2009
• Medicare & Medicaid EHR Incentive Program Notice
• f Proposed Rulemaking – January 13, 2010
• Final Rule Published – July 28, 2010
• SMD Letter: Implementation Guidance – August

2010

• SMD Letter: Removal of the National Assessment

& Accreditation Council (NAAC) Requirement – April 2011

• SMD Letter: HIE – May 2011

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Background

• August 2010 SMD letter:

– Allowable expenses for activities supporting the

administration of the Medicaid EHR Incentive Program.

– CMS expectations of activities and potential

eligible costs for the 90 percent FFP for administration and oversight of the Medicaid EHR incentive payments.

– Initial direction regarding State Medicaid agencies’

role in promoting EHR adoption and health information exchanges (HIE).

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Key Principles at Play

• Costs divided equitably across other payers

based upon the Office of Management and Budget (OMB)-defined “fair share” principle

• Costs appropriately allocated
• Activities leverage efficiencies with other Federal

and State HIE funding

• Activities that are developmental and time-limited
• Health Information Technology for Economic and

Clinical Health Act (HITECH) 90% FFP is not for

• n-going HIE costs once operational

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Other Payer Contributions/ Fair Share Principle

• Why a public/private partnership requirement?

– Efficiencies and quality improvements accrue to all participants – Governance and risks should not be borne solely or predominately by one payer – Maximize broad enough stakeholder involvement to ensure a balanced and responsive HIE market for both private and public sector health systems’ needs.

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How Much is Enough?

• A sufficient number of other payers and

investors to establish a sustainable business model

– Proportional investments based upon market

share and expected volume of transactions

• Medicaid can be the catalyst, the bait, to bring

in others but cannot be the sole funding source for a statewide HIE.

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How will CMS Assess States’ HIE- related Implementation Advance Planning Documents (IAPDs)?

• Alignment with the applicable 7 Standards and

Conditions in the recent Medicaid IT final rule

• Examination of the benchmarks and

performance measures proposed by the State, with an annual review

• Directly connected to the strategy that

Medicaid should be facilitating access to HIE for all Medicaid eligible providers in order to meet MU

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Securing/Demonstrating Other Payers’ Contributions to HIE

• Legal agreements obligated entities to share the

costs of HIE infrastructure with Medicaid

– When? – How much? – What for? – What about late entries/early investor benefits? – Governance?

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Cost Allocation for HIE

• Does anyone stand to benefit besides the

Medicaid agency?

• Is it an MMIS expenditure or a HITECH

expenditure?

– The cost allocation model varies depending

• Requests for 50% general program

administration FFP for HIE also needs justification in terms of support of the Medicaid enterprise

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Favorable Characteristics of HIE Models

• We will look at each State individually.
• However, we encourage models that:

– Deploy statewide HIE services or orchestrated

sub-state nodes

– Tie closely to Medicaid providers’ achievement of

meaningful use

– Play a role in how the Medicaid agency will collect

and validate Medicaid providers’ meaningful use data, including clinical quality measures (CQM)

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Model Characteristics Cont’d

• Provide immediate value to providers in an affordable

way

• Are governed by state-level policies, accreditation

processes and exchange standards that are aligned with Federal policy

• Are actively engaged with State government

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Justify the Model

• What is the rationale for this approach, from

the perspective of the Medicaid agency?

• If a proposed model differs from the

encouraged traits, then provide justification supporting it

• How will the HIE transition from an

infrastructure build project to an operational HIE (and how will States sustain it at that point?)

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Sustaining Operational HIE

• Adjustments to provider reimbursement

methodologies (FMAP)

– Would require a State Plan Amendment

• And/or through the 50% match rate for

general program administration, if the HIE is related to the administration of the Medicaid Program

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HIT IAPD for HIE Recap

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HIT IAPD for HIE Recap

• What do you want to fund? (break it out by

MMIS vs. HITECH)

• Who is going to ante in, how much, for what

and when? (and prove it to us)

• Why are you taking that approach?
• How will you benchmark progress, assess

risk, establish governance and a sustainable business model?

• How will you transition from build to
• perational?

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And if it’s Already Operational?

• Once live and operational, it’s no longer

applicable for the HITECH administrative matching funds in most cases

• CMS believes that it would be most

appropriate to address providers’ on-going costs related to HIE through reimbursement

• And possible through the 50% general

administrative match.

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HIT Coordinators

WE NEED YOU!

• Funding will vary depending on where they

“sit” – in the Medicaid agency? Out of the agency?

• Medicaid MU is here until 2021
• We need to understand the workload
• SMA should submit the funding request

through the HIT IAPD

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Medicaid Health Information Exchange (HIE) Discount

The Division of Health Care Finance shall develop and maintain a coordinated health policy agenda that combines the effective purchasing and administration of health care with promotion oriented public health strategies.

The Division of Health Care Finance shall develop and maintain a coordinated health policy agenda that combines the effective purchasing and administration of health care with promotion

• riented public health strategies.

Agenda

• HIE History in Kansas

– Kansas Health Information Exchange (KHIE)

• Eligible Hospitals

– Discount Model – Payments – Challenges

• Eligible Professionals

– Changes to the HIE Discount

• Future Opportunities

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The Division of Health Care Finance shall develop and maintain a coordinated health policy agenda that combines the effective purchasing and administration of health care with promotion

• riented public health strategies.

Kansas Health Information Exchange (KHIE)

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• Kansas Health Information Technology

and Exchange Act (KHITE) of 2011 formed a private corporation Kansas Health Information Exchange (KHIE)

• KHIE established a group of public and

private stakeholders to evaluate HIE needs in Kansas

The Division of Health Care Finance shall develop and maintain a coordinated health policy agenda that combines the effective purchasing and administration of health care with promotion

• riented public health strategies.

Kansas Health Information Exchange (KHIE)

• KHIE determined the state would not

provide any statewide technology services directly to health care providers in the state

– Development of privately managed Regional Health Information Organizations (RHIOs) in the state. – Provide direct service to this customer base

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The Division of Health Care Finance shall develop and maintain a coordinated health policy agenda that combines the effective purchasing and administration of health care with promotion

• riented public health strategies.

Kansas Health Information Exchange (KHIE)

• Currently two HIOs are approved:

– Kansas Health Information Network (KHIN)

• 1.1 million Kansas patient records available for

query

– Louis and Clark Information Exchange (LACIE)

• 1.75 million Kansas and Missouri patient records

available for query

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The Division of Health Care Finance shall develop and maintain a coordinated health policy agenda that combines the effective purchasing and administration of health care with promotion

• riented public health strategies.

Kansas Health Information Exchange (KHIE)

• The Kansas Health Information Exchange

Project has provided the HIOs with Office

• f National Coordinator for Health

Information Technology (ONC) grant funding:

• KHIN $4.5 million
• LACIE $1.3 million

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The Division of Health Care Finance shall develop and maintain a coordinated health policy agenda that combines the effective purchasing and administration of health care with promotion

• riented public health strategies.

Kansas Health Information Exchange (KHIE)

• Kansas Health Information Technology Act

(KHITA) transferred the responsibility of the Kansas Health Information Exchange (KHIE), to the KDHE, effective July 1, 2013

– Formed the new KDHE Office of Health Information Technology (KanHIT) – Aaron Dunkel

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The Division of Health Care Finance shall develop and maintain a coordinated health policy agenda that combines the effective purchasing and administration of health care with promotion

• riented public health strategies.

Eligible Hospitals

• Hospitals who have received a Medicaid

EHR incentive payment are eligible for a 13% discount of the anticipated HIE fees

– HIE fees include:

• Interface fee
• 2 years of subscription fees

– 13% is based on the percent of Kansans enrolled in the Medicaid program for cost allocation purposes

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The Division of Health Care Finance shall develop and maintain a coordinated health policy agenda that combines the effective purchasing and administration of health care with promotion

• riented public health strategies.

Eligible Hospitals

• The program has provided $179,392 in

funds for 27 hospitals

• Funding for Eligible Hospitals is set to

expire on 9/30/14

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The Division of Health Care Finance shall develop and maintain a coordinated health policy agenda that combines the effective purchasing and administration of health care with promotion

• riented public health strategies.

Eligible Hospitals

• Challenges

– Delayed start – EHR Vendor delays

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The Division of Health Care Finance shall develop and maintain a coordinated health policy agenda that combines the effective purchasing and administration of health care with promotion

• riented public health strategies.

Eligible Professionals

• Implementation Advance Planning

Document (IAPD) approved to provide a 13% discount to Eligible Professionals for the anticipated HIE fees

– Discount is approximately $225 per provider

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The Division of Health Care Finance shall develop and maintain a coordinated health policy agenda that combines the effective purchasing and administration of health care with promotion

• riented public health strategies.

Eligible Professionals

• Changes

– Will submit an IAPD-U to request funds to pay a larger portion of Eligible Professionals interface fee (subject to available state funds).

• Funding requested will cover FFY15 & FFY16
• No longer paying for 13% of subscription fees

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The Division of Health Care Finance shall develop and maintain a coordinated health policy agenda that combines the effective purchasing and administration of health care with promotion

• riented public health strategies.

Future Funding Opportunities

• Kansas is exploring ways to use enhanced

90/10 matching HITECH funds for activities that will help implement proposed State Medicaid HIT Plan (SMHP) services and equipment

– System and resource costs associated with:

• CMS Registration and Attestation (R&A) interface
• Collection and verification of meaningful use data from

providers’ EHRs including electronic clinical quality measures

• State interfaces with HIE, Laboratories, Immunization

Registries, and Public Health

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The Division of Health Care Finance shall develop and maintain a coordinated health policy agenda that combines the effective purchasing and administration of health care with promotion

• riented public health strategies.

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Christina Rondash crondash@kdheks.gov www.kdheks.gov/hcf/hite/default.htm

The Division of Health Care Finance shall develop and maintain a coordinated health policy agenda that combines the effective purchasing and administration of health care with promotion oriented public health strategies.