CMS EHR INITIATIVE PROGRAM UPDATE
How many changes have you experienced since you began working in the world of IDD Services? What’s your typical response? Do you fight change, clinging to the “good old ways,” kicking and screaming? Do you endure change, dragging your feet and suffering in silence? Or do you embrace change, leading the way to true progress through innovation and enthusiasm?
One inevitable change in our world is the shift from paper-based documentation systems to interactive, interoperable systems that will enable true interdisciplinary approaches to services. This is where the CMS Promoting Interoperability Program (previously EHR Incentive Program) comes in.
In 2011, CMS established the Medicare and Medicaid EHR Incentive Programs to encourage Eligible Professionals (EPs) and eligible hospitals, to adopt, implement, upgrade (AIU), and demonstrate meaningful use of certified EHR technology. This marked the start of CMS’s dedicated efforts to improving interoperability and patients’ access to health information across the board. By attaining some pre-set quality goals, facilities could begin earning incentive payments and increase revenues.
In 2015, CMS proposed a rule that would require long-term care (LTC) facilities and nursing homes to participate in health information exchange. The intent was that during a patient transfer or discharge, long-term care facilities would be required not only to document an event in the patient’s clinical record, but also to transmit that information to the receiving facility in order to promote continuity of care.
First, EHR use was incentivized, or rewarded. Then, it was a requirement…….see a trend here?
Just last month (August 2018), a further rollout of this program was announced. First of all, CMS has renamed the ‘EHR Incentive Programs’ the ‘Promoting Interoperability (PI) Programs’. CMS has also extended the requirement to include the Long Term Care Hospitals Prospective Payment System. Once the various hospital type facilities have received CMS payment incentives (or penalties), ‘Care in the Community’ service providers will likely be a subsequent target for CMS to implement similar EHR interoperability mandates. Long Term Care Provider payments (or penalties) linked to EHR/interoperability initiatives seem inevitable and plans for future expansion into this arena are already mapped out.
At this point, it’s more a matter of ‘how soon’ than ‘if’. CMS payments to long term care/home health facilities will be based on providers attaining quality metrics that are predetermined, measurable and trackable with an emphasis on the use of EHRs and other electronic means of communication between care providers as well as between care providers and the patients/clients (or caregivers) they serve. Although the eligibility standards and meaningful measures will almost definitely be very different from those expected from acute care institutions, attainment of the standards will be required for payment of incentives (or avoidance of penalties).
There is no denying that the use of EHRs to document services can increase efficiencies, decrease errors and reduce costs when used effectively. With the massive long term care budget cuts passed under the Bipartisan Budget Act of 2018, providers will no longer be able to run things the old, inefficient way by hiring more and more staff. New ways of thinking, working and administrating will be critical for the survival of IDD service companies. Those companies that refuse to change will fail.
According to the Congressional Budget Office (CBO), there is a $3.5 billion Medicare cut to home health services, and a $1.9 billion Medicare cut to nursing home care. The CMS definition of home health includes care in the community settings; the program names may differ by state but literally all long term care in the community agencies will be impacted. While the cut will not begin until 2019 for home health, it starts Oct.1 2018 for nursing homes with $140 million slashed from care. As we all know, that which begins in Medicare will trickle down to Medicaid. How long until YOUR operations are affected?
“Change is inevitable, but progress is optional.” – Tony Robbins
The time to start making changes is NOW! Ask yourself – where will I contain costs? What is my highest budget item? What will I do to maintain (and exceed) acceptable quality of consumer care requirements and turn a profit? These difficult questions must be answered sooner rather than later. Burying your head in the sand, working hard and hoping that legislators will recognize your blood, sweat, tears and dedication will not work. Automation is a key (if not the key) to controlling the largest of budget costs, which it does by increasing staff efficiencies and reducing ancillary costs. No matter the size of your organization, paying for an EHR system that costs a fraction of a full time employee makes sense! (Also, EHRs don’t require benefits or rest periods while doing the work of a couple of FTEs.)
Of course, this will demand effort, commitment and leadership skills from owners and administrators but if you choose the right EHR (see Focused Software’s extensive list of solutions) you’ll get all of the customer service, online tools and tech support you need.
The services IDD providers afford this vulnerable population are critical! Providers owe it to themselves, their clients/consumers and family stakeholders, as well as their team members, to do all it takes to survive, and thrive, in this new reality. Strong leaders with great integrity will be needed to avoid the unnecessary demise of many IDD service organizations. As the budget cuts come through and margins lessen this rules out the knee-jerk response of just hiring more staff (your most expensive cost item).
Implementing Focused EHR is easier than you think! Once your direct care staff easily input consumer and service provision data within our EHR, the data can be manipulated to provide output in different formats to facilitate billing, payment, and utilization/quality management tasks and reports. Automation is the smart and most affordable answer! Call FOCUSED SOFTWARE TODAY!
Implementing an Electronic Health Record NOW can better prepare you for the CMS changes to come