Imagine you go to work one day and your boss says all employees will be evaluated based on the performance of a new set of job skills that require additional training and, perhaps, new computer hardware and software. The boss also announces that some employees will be reimbursed for the cost of acquiring these skills and tools. You aren’t among this privileged group.
In government, this is called an unfunded mandate. The unlucky employee in this case is psychiatric hospitals, who aren’t eligible for Meaningful Use incentives even while Congress and the Obama administration have legislated greater accountability:
A precursor to the 2010 Affordable Care Act (ACA), the Mental Health Parity and Addiction Equity Act of 2008 mandated that insurers must make the financial cost of benefits—co-pays, deductibles, out-of-pocket maximums—equal for psychiatric and physical care.
By making behavioral health an Essential Health Benefit, the ACA requires health plans to cover mental health on par with other types of care.
On October 1, 2012, CMS launched the Inpatient Psychiatric Facility Quality Reporting Program (IPFQR), a pay-for-reporting program in which facilities could lose federal dollars by not providing data on Hospital Based Inpatient Psychiatric Services (HBIPS):
- Screening for violence risk, psycho trauma Hx, patient strengths
- Hours of physical restraint use
- Hours of seclusion use
- Patients discharged on multiple antipsychotic medications
- Patients discharged on multiple antipsychotic medications with appropriate justification
- Post discharge continuing care plan created
- Post discharge continuing care plan transmitted to next level of care provider upon discharge
Whether explicit or implicit, these programs amount to unfunded EHR mandates. How so?
Organizations still on paper records will find it expensive and inefficient to capture events and collect results for both reporting to government and submitting claims to insurance companies. Hospitals will need to train clinicians to document post-discharge continuity of care plans.
They will have to train staff to send plans by snail mail or fax to the provider at the next level. Then they will also need to do chart reviews to assure that all these steps took place and the data is recorded in a spreadsheet or database. Any quality improvement process that requires benchmarking and scoreboarding of performance based on these measures will be a tremendous challenge using paper records.