Hundreds of responses to the 2015-2020 Federal Health IT Strategic Plan are now available for viewing online. CAST and the Long Term and Post-Acute Care Health Information Technology Collaborative (LTPAC Health IT Collaborative) each submitted a 4-page response to the draft strategic plan.
CAST is a member of the Collaborative and played a central role in writing the comments.
The Office of the National Coordinator of Health Information Technology (ONC) released the draft strategic plan in December. ONC plans to review the comments and publish a revised draft later in 2015.
CAST reported in December that the draft Health IT Strategic Plan calls for wider adoption of health IT across the care continuum. The draft plan:
- Acknowledges that use of health IT remains low among providers practicing in long-term services, post-acute care and behavioral health settings.
- Calls for expanded adoption of electronic health records (EHR), telehealth and mobile health in these settings.
- Supports increased assistance for organizations that were not eligible to participate in the Medicare and Medicaid EHR Incentives Programs.
CAST and Collaborative Comments
In our comments, CAST and the LTPAC Health IT Collaborative applauded the inclusion of LTPAC in the strategic plan’s definition of “provider,” and agreed with the plan’s broadening of health IT to include telehealth and mobile technology.
But we also called attention to the barriers that must be addressed before adoption of health IT becomes widespread within the LTPAC sector.
“We encourage the Department of Health and Human Services (HHS) to continue with a more focused effort—one that is centered on high-value strategies as well as a set of LTPAC-specific programs and activities that allow all providers to be engaged in the process and that increase networking across the health care spectrum,” wrote CAST and the Collaborative.
Specifically, CAST and the Collaborative made recommendations in the following areas:
- Inclusion of LTPAC: We urged ONC to serve as a convener that brings together all stakeholders, including technology leaders serving the LTPAC sector, to develop a national IT strategy that engages LTPAC providers more meaningfully. We asked HHS to consider a variety of strategies—including direct incentives, telehealth reimbursement, health IT grants, no/low-interest loans and no/low-cost technical assistance—to encourage LTPAC providers, including small and rural providers, to adopt of health IT and participate in health information exchange (HIE).
- Telehealth adoption: CAST and the Collaborative supports the expanded adoption of telehealth, mobile and remote-monitoring technologies, which have the potential to lower the cost and improve the efficiency of care, reduce unplanned hospitalizations, engage patients, and increase care coordination. We urged ONC to explore how all of these technologies can enhance new payment models, like accountable care organizations, with the goal of providing integrated, person-centered care and services in less restrictive and less costly settings. We urged ONC to consider reimbursement as a tool to drive the adoption of telehealth technology.
- Telehealth restrictions: Section 1834(m) of the Social Security Act restricts Medicare reimbursement to a limited number of Medicare Part B services furnished through particular telecommunications systems and only to beneficiaries who can reach specific “originating sites.” CAST and the Collaborative urged HHS and the Centers for Medicare and Medicaid Services (CMS) to consider eliminating a number of these restrictions.
- Demonstration programs: We urged ONC to work with CMS and the Centers for Medicare and Medicare Innovation to develop demonstration programs that are focused on, or led by, LTPAC providers. These programs should emphasize health IT and innovative operational and payment models that offer incentives for the adoption and meaningful use of technologies.
- Infrastructure: We urged ONC to advocate for funding from the Federal Communications Commission to expand broadband in both rural and underserved urban areas. This expansion is necessary to advance the adoption and use of telehealth and other technology.
- Interoperability: LTPAC providers are important partners for acute care providers. The success of these partnerships depends on the ability of both partners to use health IT and to exchange relevant health information electronically. CAST and the Collaborative asked ONC to recognize how the Improving Medicare Post-Acute Care Transformation (IMPACT) Act, which is driving standardized assessment and quality measure reporting for LTPAC, will affect interoperability. We urged ONC to investigate ways to relate the IMPACT data set with future Meaningful Use requirements for HIE at transitions of care.
- Data exchange for shared care: Finally, we urged ONC to take steps to facilitate information exchange among LTPAC providers, pharmacies, and physicians who have adopted certified EHR technology. In addition, ONC should support communication and coordination between patient/family caregivers and members of the professional caregiving team, particularly for individuals with chronic conditions and multiple co-morbidities. Areas of priority should include interoperable exchange of data for accurate medication reconciliation and management; exchange of a patient’s advanced directives; and coverage for end-of-life care services for Medicare patients.