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 7/28/2014 2
ACA Operating EHR Rules and LOINC PCMHs Incentive Standards Programs CCDA HIE ICD-10 PQRS SNOMED e-reporting IQR e-reporting 5010 ACOs 3
Interoperabilty 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 4
eHealth Transformation as Standardization 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 5
Policy & Program Levers Medicare and Medicaid EHR Incentive Programs Administrative Simplification, including ICD-10 Quality Data, Quality Measures Health Information Exchange 6
“Administrative Simplification” & ICD-10 » Standardized operating rules » Standardized benefit coverage information Administrative » Standardized benefit utilization information Simplification: » Standardized timeliness of query response » Standardized referrals and pre-authorizations » Reimbursement » Research ICD-10 will » Quality measurement improve: » Public health » Organizational monitoring and performance 7
EHR Meaningful Use (MU) & Interoperability Stage 1 Stage 2 Stage 3 (began in 2011; starting (to be implemented in (expected in 2016) point for all providers) 2014 under the final rule) Focus: Focus: transferring Focus: online demonstrating that data to EHRs and access for patients quality of health being able to share to their health care has been information information and improved electronic health information exchange between providers 8
EHR Meaningful Use & Interoperability Standardization through Stages Stage 1 Stage 2 Stage 3 Standardized ??? Standardized Data Data Exchange • • Problem list Consolidated • Clinical Medication list • Etc Document Architecture (CCDA) • DIRECT More Data 9
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 10
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 11
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 7/28/2014 12
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 7/28/2014 13
The Connection Points • Consumers Electronic Health • Providers Records • Vendors • Consumers Health Information • Providers • Payers Exchange • Vendors • Consumers Health Insurance • Payers/Issuers Marketplaces • Vendors • Consumers Eligibility , Enrollment • Providers and Claims Processing • Payers Systems • Vendors 03/27/2013 14
Why Look at Commonalities? A coordinated vision and enterprise perspective on 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 7/28/2014 15
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 States are building incrementally. HIEs are building incrementally. MMIS and E&E are being transformed. Do a gap analysis for your 2015 vision! 7/28/2014 16
Guidance Overview • American Recovery & Reinvestment Act – February 2009 • SMD Letter: Planning Guidance – September 2009 • Medicare & Medicaid EHR Incentive Program Notice of 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 7/28/2014 17
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). 7/28/2014 18
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 on-going HIE costs once operational 7/28/2014 19
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. 7/28/2014 20
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. 7/28/2014 21
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 7/28/2014 22
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? 7/28/2014 23
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 7/28/2014 24
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) 7/28/2014 25
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 7/28/2014 26
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