ONC’s most recent request for comments (RFC) on the subject of their 2015 electronic medical records (EHR) guidelines has led to some confusion within the provider community – including home health and hospice providers. NAHC’s affiliated Home Care Technology Association of America (HCTAA) recently submitted public comments that are specific to the sections of the 2015 rule that were identified as priorities for the home care and hospice community. It is important to reiterate that there is no mandated HER requirement for home health or hospice providers in the proposed 2015 HER rule, which is voluntary.
The proposed 2015 voluntary EHR Certification Program includes a section on a proposal for a non-Meaningful Use EHR Certification program for Long-Term Post-Acute Care (LTPAC) providers. This provision serves as a bridge to support an ONC Certification program for home care and hospice EHR products that would be fully electronic except when a provider gives a patient a hard copy of their summary care record.
HCTAA has also been engaging with the ONC’s Health IT Policy Committee (HITPC) on the development of a voluntary EHR certification program for LTPAC. HCTAA’s comments and recommendations are reflected in both the 2015 comments and also in comments provided to the HITPC Adoption and Certification Work Group in December of 2013.
In HCTAA’s comments on the Summary Care Record, the organization outlines that the CCDA clinical architecture would serve as the means for transferring health care data upon transition of care and be supported by EHR-to-EHR interoperability. In practice, this would mean that each provider would have their own EHR system but could accept information from other systems e.g. interoperability.
With respect to requiring patients to access their records on-line, HCTAA did not support a Patient Engagement Package proposed by ONC, but decided to focus on the need for the exchange of health information between hospitals, physicians, home health agencies and hospices.
Most likely, if HCTAA’s EHR program is supported by the CCDA, then third party vendors, such as the Microsoft Health Vault, could accept information from the EHR if that system was to match those data fields using the CCDA.
Currently, summary care records that are sent via the DIRECT standard are PDF are acceptable to ONC for Stage 2 Meaningful Use. HCTAA would prefer ONC move to a field-to-field match where data could be sent, received, and also made reusable by the home health agency for the purpose of completing the patient assessment. That functionality, however, will not be supported until Stage 3 of Meaningful Use, and those stages have been sliding back.
HCTAA suggests that if the member in not an Eligible Professional (EP) or Eligible Hospital (EH) that is receiving incentives through the Meaningful Use Incentive Program then they shouldn’t be concerned with a mandate since it doesn’t apply to them.
HCTAA has been adamant that it does not support an unfunded mandate, and that HCTAA is still seeking incentives for the adoption of EHRs by home health agencies and hospice providers. HCTAA will continue to work with and engage with the federal government to create common sense approaches to encourage the sharing of electronic health information. HCTAA encourages home care and hospice providers to adopt EHR technologies
There is a lot of information provided in HCTAA’s comments, which will help to explain NAHC/HCTAA’s position on HER policy.
To read HCTAA’s April 2014 comments, please click here.
To read HTCAA’s December 2013 comments, please click here.