An expanded interpretation of HITECH federal funding for state-related health data exchange activities means additional resources are available to health information exchange helping Medicaid providers meet the requirements of modified Stage 2 and Stage 3 Meaningful Use.
In a letter sent earlier this year to state Medicaid directors, the Centers for Medicare & Medicaid Services (CMS) noted an important change to its interpretation of State expenditures eligible to be matched by federal funding under the Health Information Technology for Economic and Clinical Health Act — the 90/10 HITECH match.
“We now explain that State costs of facilitating connections between Eligible Providers and other Medicaid providers (for example, through an HIE or other interoperable systems), or costs of other activities that promote other Medicaid providers’ use of EHR and HIE,” wrote Director Vikki Wachino in late February, “can also be matched at the 90 percent HITECH matching rate, but only if State expenditures on these activities help Eligible Providers meet the Meaningful Use objectives.”
The CMS letter makes clear that the 90 percent HITECH match, which is subject to federal agency approval, applies to a specific set of meaningful use requirements for eligible providers in the Medicare EHR Incentive Program — that is, “the ability to electronically coordinate with other providers across care settings” in modified Stage 2 and Stage 3 Meaningful Use.
The CMS decision stems from a recognized need to promote health data exchange and advance healthcare interoperability in concert with the Office of the National Coordinator for Health Information Technology .
CMS explicitly encourages and welcomes multistate collaboratives partnering on shared solutions for HIE and interoperability, including for the activities discussed in this letter (facilitation of EHR Meaningful Use and related communications through the HIE system). CMS will aggressively support such collaboratives as potentially cost-saving opportunities to increase adoption of interoperability standards and help Eligible Providers demonstrate Meaningful Use. Such collaboratives should promote Medicaid Information Technology Architecture (MITA) principles on scalability, reusability, modularity, and interoperability. We note that ONC is a willing partner in helping States develop open source and open architecture tools for HIE that are consistent with MITA principles.
States seeking the 90/10 HITECH match are responsible for reporting to the federal government how the funding they are providing to eligible providers are enabling the latter to demonstrate meaningful use HIE-related requirements, including an Implementation Advance Planning Document (IAPD) tying their activities to specific measures.
The expanded interpretation of HITECH funding includes two categories of activities for which they can receive federal matching dollars — onboarding Medicaid providers to HIEs or interoperable systems and connecting eligible providers to other Medicaid providers via either pathway.
For the first category, states could also claim 90 percent HITECH match for costs associated with onboarding pharmacies, clinical laboratories, and public health providers.
The second category pertains to interoperability and HIE architecture, such as in the design, development, and implementation of :
- providers directors
- secure electronic messaging
- query exchange
- care plan exchange
- encounter alerting
- public health systems
- health information services provider
“This is not an exhaustive list of the types of state costs for design, development, and implementation of HIE components and interoperable systems for which 90 percent HITECH match might be claimed,” Wachina explained. “Design, development, and implementation costs associated with other HIE components and interoperable systems might be supported by the 90 percent HITECH match as long as these costs help Eligible Providers achieve Meaningful Use and meet the cost controls described above, and will be considered by CMS accordingly.”
As CMS concluded in the letter, the motivation behind the expanded interpretation is two-fold: to help eligible providers demonstrate meaningful use in the Medicaid EHR Incentive Program and to increase health data exchange among these providers, both eligible and ineligible Medicaid providers.