The move toward an interoperable electronic health care data system has been stimulated by a system of incentives, penalties and pay adjustments for providers. The CMS EHR Meaningful Use (MU) programs were a prime example of this process. It was the proverbial carrot and stick approach. Meet the requirements and gain incentives or just ignore the whole thing and maybe get dinged down the road. Over the past decade, Medicare reimbursement has been affected by a combination of MU, e-prescribing and quality reporting programs. All those are now coming together in the unified MACRA/MIPS Quality Payment Program. This is a giant step up in terms of how reimbursement could be dearly affected by not moving along what used to be called the “electronic highway”. Under MACRA/MIPS, affected providers will see a significant widening of the “fee adjustments”, either up or down, depending on their ability to meet the Quality Payment Program regulations. The push toward “pay for value”, on a foundation of electronic requirements and structured data, was initially driven by CMS at the national level. We are now seeing this being played out on the state level. Until recently Medicaid providers have been basically shielded from potential fee adjustments related to the use of health information technology. That is ending and we can see stark examples on the horizon for Medicaid providers.
Beyond penalties and incentives what other leverage is coming to convince providers to join the electronic health data revolution? Well, how about a 100% penalty? NC legislation passed in 2015 informs us that:
- By February 1, 2018, all Medicaid providers must be connected and submit data to the HIE in order to continue to receive payments for Medicaid services provided.
- By June 1, 2018, all other entities that receive state funds for the provision of health services, including local management entities/managed care organizations, also must be connected.
That’s right, Medicaid providers in NC will not be eligible to be reimbursed unless they are sending properly formatted files with structured data twice a day to the state HIE. Any way you look at it that is a 100% penalty. Many of the affected providers, especially those who provide behavioral health services, don’t even have an EHR. For quite a few Medicaid providers in NC, dependent on paper documentation and physical charts, time is running out. As Bob Dylan sang, “It may not be dark, but it is getting there”.