EHR Rule Could Preclude Hospices from Primary Care First

Requirements for electronic health record (EHR) interoperability could preclude some hospices from participating in Medicare’s Primary Care First payment models. The U.S. Centers for Medicare & Medicaid Services (CMS) requires health care organizations that participate in the model to use certified EHR technology (CEHRT).

CEHRT are IT products that comply with criteria established by CMS for certain programs, such as the Merit-Based Incentive Payment System. The Office of the National Coordinator (ONC) maintains the standards, which exist in multiple editions. Providers would have to comply with the 2015 edition for Primary Care First.

CMS has given hospice and palliative care providers a one-year grace period for the CEHRT requirement, meaning that participating providers would have until Jan. 1, 2021 to bring themselves into compliance.

“We recognize that hospice and palliative care organizations may lack the financial resources to comply with CEHRT requirements in year one of the model,” said Michael Lipp, chief medical officer of the Center for Medicare & Medicaid Innovation (CMMI), a component of CMS, in an agency webinar. “Practices can request one-year implementation delay for the CEHRT requirement and begin using CEHRT at the beginning of performance-year two.”

However, this grace period may not be sufficient to allow for hospices to catch up. Very few, if any, hospices use CEHRT systems, and switching EHR vendors is an expensive and time-consuming undertaking. Moreover, most vendors do not offer CEHRT in their product lines for hospices.

“We are very excited about the payment models; we are always interested in ways to expand our offerings, and this seems like a [patient] population that could really use the help that our interdisciplinary teams provide,” said Tony Kudner, vice president of communications for Illinois-based Seasons Hospice & Palliative Care. “But the problem with CEHRT in particular is that the [hospice] industry isn’t big enough for the EHR providers to embrace CEHRT for their hospice software. The one-year waiver sounds like a step in the right direction, but I doubt that the technology would be there by 2021.”

Seasons uses one of the largest EHR vendors that serve hospices, Kudner told Hospice News. The vendor told them that they have no immediate plans to develop CEHRT products for their hospice line.

This is an industry-wide concern that could affect most hospices.

“The CEHRT requirement is a problem for independent hospices and palliative care practices,” Allison Silvers, vice president of payment and policy for the Center to Advance Palliative Care, told Hospice News. “It is not a level playing field. Many [health care providers] received financial support from the federal government to adopt CEHRT through the Meaningful Use program, and hospices, as Part A providers, did not, so that the CEHRT investment for SIP will fall 100% on those providers. The one-year delay is helpful, but does not address the inequity or the investment needed.”

CMMI applied the stipulation because the Medicare Access and CHIP Reauthorization Act of 2015 requires CEHRT for any advanced alternative payment model, Silvers explained. The technology is designed to improve care coordination, which is a key tenet of Primary Care First.

Though the requirement could prevent many hospice and palliative care providers from participating in the new payment models, they are not without options. CMS has instituted a direct contracting program that would allow organizations such as hospices indirect access to emerging, risk-sharing payment models by partnering with other providers involved in the program, such as primary care practices, without having to satisfy every requirement.

“You want to find out if anyone in your geography is going to participate in direct contracting. If they are, you want to have a conversation with them about contracting with them. All of the requirements are going to be at the primary direct contracting level,” said Lori Bishop, vice president of palliative and advanced care for the National Hospice & Palliative Care Organization, in a conference call with the industry group’s members. “You as a preferred partner will not be required to meet those [stipulations], such as CEHRT.”

CMS will begin implementing Primary Care First in Jan. 2020, initially in 26 regions throughout the United States. The first quarter of 2020 would focus on provider and patient on-boarding, and the new payment systems would become effective in April of that year. Hospices and palliative care organizations are eligible to participate in the payment models provided they meet the program’s criteria. The program is designed to reduce costs and hospitalizations as well as improve care coordination.

Eligible providers can choose to participate in one or both of two payment options under the program: A general payment option and a Seriously Ill Population payment option designed to serve patients with complex, chronic needs, through which providers focused on caring for that population would receive increased payments.

“We are hopeful that CMS can look into the field and provide some solutions [to the CEHRT issue]. That’s going to be an impediment for most providers to comply with, and that’s unfortunate because the model seems like it really does solve some pain points for a lot of patients,” Kudner told Hospice News. “These patients could really benefit from the type of interdisciplinary, patient-centered care that hospice and palliative care providers are the experts at providing, and that through no fault of their own most primary care practices are not.”