The Centers for Medicare and Medicaid Services (CMS) didn’t target its latest set of draft regulations for the electronic health record (EHR) incentive program to long-term and post-acute care (LTPAC) providers.
But, the proposed regulations, which will govern Stage 3 of the Meaningful Use program, could mean more interoperability and health information exchange opportunities for LTPAC providers.
Hospitals, physicians and other eligible professionals will be expected to comply with the rules by 2018, according to Modern Healthcare. Those who fail to meet the requirements could pay $500 million in Medicare penalties between 2018 and 2020.
Objectives of the Rules
The draft rules set out 8 areas of program objectives for 2017 and beyond. Those objectives address:
- Protection of Patient Health Information.
- Certified EHR Technology.
- Electronic Prescribing.
- Clinical Decision Support.
- Computerized Provider Order Entry.
- Patient Electronic Access to Health Information.
- Coordination of Care through Patient Engagement.
- Health Information Exchange.
- Public Health and Clinical Data Registry Reporting.
Measures Affecting LTPAC
The Health Information Exchange (HIE) objectives have the most applicability to LTPAC settings. That’s because LTPAC providers will be expected to help their health care partners meet the Meaningful Use requirements when patients transition into LTPAC settings.
CMS is proposing that professionals, hospitals and critical access hospitals that are eligible for the EHR incentive programs must successfully meet the threshold for 2 of the following 3 proposed HIE measures:
- A provider that transitions or refers a patient to another setting must use a certified EHR to create and electronically share a summary of care record for more than 50% of transitions of care and referrals.
- In cases where the eligible provider had never before encountered a patient, the provider must incorporate an electronic summary of care document into the patient’s EHR. That summary must come from a source other than the eligible provider’s EHR system. This measure would apply to more than 40% of transitions, referrals or new patient encounters.
- A provider would have to perform a clinical information reconciliation for more than 80% of transitions, referrals and patient encounters in which the provider had never before encountered the patient. To fulfill this requirement, the provider would have to implement clinical information reconciliation for medications, medication allergies and current problems, and send that information electronically to the receiving provider.
CAST believes that these measures would potentially drive more meaningful health information exchange with other health care providers.
Public Comments Period
Comments on the proposed rule are due May 29. Please let me know if you have specific comments on the proposed rule you’d like CAST to consider incorporating.