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Michael Petruzzelli

, National Council for Mental Wellbeing

CMS Proposes Important Updates to EHR Incentive Program

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For behavioral health providers participating in Electronic Health Records (EHR) Meaningful Use incentive program, there is a lot to like in the recently-proposed rules from the Centers for Medicare and Medicaid Services (CMS). Over the last few weeks, CMS has released proposed updates to the incentive program that seek to simplify reporting requirements for providers and align program objectives and measurements throughout all three stages of Meaningful Use.


Proposed Changes to Stages One and Two

For Stages One and Two, CMS has proposed streamlining objectives and measures to reduce redundancy or duplication in reporting as early as this year. The rule instead emphasizes reporting measures that achieve “advanced EHR functions” such as health information exchange, quality measurement, and quality improvement.

The proposed rules would also make changes to the reporting periods for providers: first, moving to calendar-year reporting beginning January 1, 2016; and second, changing the 2015 reporting period to a 90-day period. In order for participating providers to receive incentive payments, they must prove to CMS that they are completing a set number of requirements and demonstrate a meaningful use of the health information technology. These changes allow providers to advance more quickly through the certification process and continually collect incentive payments.

CMS notes that while it does not believe these changes would impact the overall financial estimates for incentive payments or net costs associated with the program, it estimates that these changes could save providers $50-60 million in reduced reporting burdens.


Proposed Changes to Stage Three

The Stage Three proposed rule, released in March, opens the doors for improved data-sharing between behavioral health providers and other health system partners by addressing longstanding barriers in the electronic exchange of “specially protected” health information, including mental health and substance use records.

Of high importance to behavioral health providers is the inclusion of HL7 “Data Segmentation for Privacy” (DSAP) standards in 2015 Edition EHRs. With the advent of health information exchanges and the increasing use of EHRs, sharing specially protected patient health information has been a particular focus of many debates. DS4P data and technology standards leverage existing information technology to resolve this and many other concerns around sharing this information. The availability of these standards brings health care in general and behavioral health as a field much closer to attaining that elusive goal of interoperability.

2015 Edition Certified EHR Technology (CEHRT) should be widely available by 2018, when standard and requirements for Meaningful Use become mandatory for Medicare eligible professionals. However, financial barriers to adopting CEHRT and the need for technical assistance infrastructure to support adoption persist for behavioral health providers. The National Council will continue its efforts to ensure the inclusion of behavioral health providers in the emerging community and national networks of patient care.