Thursday, February 25, 2016

HHS Considers adding behavioral health to EHR Incentive Programs Plan

If the Department of Health and Human Services has its way, it will be adding behavioral health contributors to the EHR (Electronic Health Record) Incentive Programs.


That category of contributor involves psychiatric hospitals; residential and outpatient mental health; community mental health center and substance abuse disorder treatments services; as well as psychologists.


Presently, federal rules prohibit behavioral health contributors treating mental and substance abuse disorders from getting Incentive Programs payments for executing EHRs that meet Meaningful Use criteria. Although, in its Fiscal Year 2017 budget submission to Congress previous week, HHS involved a legislative proposal to add certain behavioral health contributors to the EHR Incentive Programs.


“The expansion is meant to facilitate and serve the integration of behavioral health and medical care, and empower the sharing of clinical data required to offer improved patient-centered care,” HHS claims in its proposal.


The intended inclusion of behavioral health contributors comes on the heels of a bill launches previous year by Reps. Tim Murphy (R-Penn.) and Eddie Bernice Johnson (D-Texas). That bill, called the Helping Families in Mental Health Crisis Act, would permit behavioral health and addiction treatment contributors to get payments though the EHR Incentive Plans.


“We highly support advancing the utilization of information technologies, involving EHR systems, to support integrated behavioral healthcare,” claims Dina Passman, acting team lead for health IT at the Substance Abuse and Mental Health Services Administration (SAMHSA), the agency within HHS that leads public health attempts to advance behavioral health. “Extending incentive programs or any funding chances for the field to involve more behavioral health contributors than have initially been covered supports our objectives.”


Cara English, director of the Doctor of Behavioral Health program at the Cummings Graduate Institute for Behavioral Health Studies, is also a supporter of attempts to expand Meaningful Use incentives eligibility to involve mental health treatment facilities, psychiatric hospitals and substance abuse treatment facilities, as well as clinical psychologists and licensed social employees.


English is observing “a transition of the healthcare industry from siloed, single contributor agencies to a real model of collaborative care across a community of independent contributors. This is a sea change within healthcare in which we work together utilizing our electronic EHRs—that is never been done before—to approach the behavioral and emotional component of care and contributors that have been missing all along. In the end, it is all about sufferers and making better the quality of their care.”


Passman discusses that data daily issued by the Office of the National Coordinator for Health IT indicates that the EHR Incentive Programs have “improved uptake” of eligible experts and hospitals in accepting HIT. “We could therefore consider that would also be the case if behavioral health contributors were also involved,” she claims. “There is surely a great amount of interest in the utilization of HIT among our stakeholders and also many queries around not merely how to fund that technology but what the steps are in achieving it and applying it in a treatment setting, and all that that entails.”


Not shockingly, in accordance to Erin Dormaier, transformation services manager for the Colorado Regional Health Information Organization (CORHIO), EHR adoption amounts for behavioral health contributors have been much lower in comparison with other contributor groups that have been eligible for the Meaningful Use program. “It is surely required to pull them into the program,” states Dormaier. “They have really missed out on the incentive payments that could assist them to adopt this technology.”


Nevertheless, Toria Thompson, CORHIO’s behavioral health data exchange coordinator, makes the case that few community health centers in Colorado that employ huge numbers of psychiatrists have already benefitted from Meaningful Use payments to finance the electronic health record projects. Thompson also point outs that most, if not all, of the state’s 17 community mental health centers have electronic health records. “Although, there are other contributors in Colorado, like substance use disorder treatment centers that are usually smaller agencies and have not made investments and contributions in EHRs, who would benefit extremely.”


English, although, is not concerned that behavioral health contributors are behind in executing and utilizing EHRs, compared with others that have been engaging in the Meaningful Use program for years now, nor does she consider they will have a hard time catching up.


“As a behavioral health provider myself, I have been utilizing an EHR and we have Meaningful Use constructed into the system that we use at my medical clinic,” English emphasizes. “At the similar time, behavioral health contributors would benefit from the similar kind of technical support that other contributors have got in being capable to hit the ground running.”


“The behavioral health community has already been in loss by being less capable to get support to execute these systems, so any assistance is acknowledged and moves the field forward,” adds SAMHSA’s Passman. “All contributors who are on boarding this technology could utilize extra help. There is surely a requirement for technical assistance to help move the behavioral health field forward with this technology.”




“The intention of motivating behavioral health contributors to get EHRs is so that we can all be on the similar team,”



While Andrew Boyd, MD, a health informatics professor at the University of Illinois at the state of Chicago, is in favor of adding behavioral health contributors to the EHR Incentive Programs , he contends that there are huge hurdles to the sharing of behavioral health data that Congress may not be capable to solve, namely the fact that these records are presently inaccessible deployed on policy restrictions and state laws. Additionally, Boyd points out that the definition of “behavioral health contributors” varies state by state, deployed on regulations governing who is licensed to practice.


“The intention of motivating behavioral health contributors to get EHRs is so that we can all be on the similar team,” claims Boyd, whose research concentrates on EHRs and the places of data simplification and integration. “Storing behavioral health information in an EHR is a great 1st step, but we have a culture and policy atmosphere that prohibits this from becoming a reality. Even if we can alter policy, changing contributor attitudes is going to be even tougher.”


To alleviate few of the hurdles to data sharing, SAMHSA previously this month issued a proposed rule modifying 42 CFR Part 2, a portion of federal law that restricts the disclosure of identifiable data by a federally assisted substance abuse treatment program to any entity, even for treatment, without signed consent from the sufferer to authorize the disclosure, with restricted exceptions. It also limits the re-disclosure of that information by the acquiring entity for any intention without consent.


“The last substantive update to these regulations was in the year 1987,” claims SAMHSA’s proposal, which is presently open to public comment. “Over the last 25 years, primary changes have appeared within the U.S. healthcare system that were not envisioned by the present regulations, involving new models of integrated care that are constructed on a foundation of data sharing to support coordination of patient care, the establishment of an electronic infrastructure for managing and exchanging patient data, and a latest focus on performance measurement within the healthcare system. SAMHSA needs to make sure that sufferers with substance use disorders have the capability to participate in, and benefit from new integrated healthcare models without fear of putting themselves at threat of adverse outcomes.”


These confidentiality rules were established to offer sufferers confidence in getting substance abuse treatment without fearing disclosure of the treatment. SAMHSA’s Passman appreciates that there are problems linked with EHRs and substance abuse and alcohol treatment information.


Although, Deborah Peel, MD, founder of the organization Patient Privacy Rights and a practicing psychiatrist/psychoanalyst, considers this SAMHSA proposal will ruin the privacy required for treatment for substance abuse and psychiatric diseases.


“It will drive millions more persons away from finding treatment for diseases that can really drive them to death by overdose or suicide,” asserts Peel. “Today 50% of the public lies and omits health data when finding treatment because EHRs disclose and sell their information without their consent. The public knows their electronic records are controlled and managed by the health technology industry and are not private. So they act to s themselves by hiding data or delaying or ignoring treatment. Today’s EHRs cause bad health results.”


Boyd accepts that historically there has been a “special trust” between the behavioral health contributors and sufferers. As a result, these contributors almost never surrender behavioral health notes—like psychiatric and psychotherapy notes—even for court cases, he claims.


“From a medical perspective, sharing few or all of the records makes sense, and behavioral health contributors using EHRs is a great 1st step,” Boyd summarizes. “But, we should have a discussion on a national basis about what is and is not suitable, identifying this special relationship between behavioral health contributors and sufferers. It is a delicate balancing act.”


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