On June 11, 2017, the Centers for Medicare and Medicaid Services (CMS) issued a letter to State Medicaid Directors providing guidance on which funding authorities states can leverage for health information technology, telemedicine, and prescription monitoring solutions specifically targeted to help combat the opioid crisis. This letter directly responds to the information technology recommendations outlined in the November 1, 2017, President’s Commission on Combating Drug Addiction and the Opioid Crisis Report, the October 26, 2017, Declaration of a Nationwide Public Health Emergency by the Acting Secretary of Health and Human Services along with the agency’s 5-Point Strategy to Combat the Opioid Crisis.
HIMSS applauds CMS’ commitment to utilizing 21st century healthcare solutions including telehealth and prescription drug monitoring programs (PDMPs) to address the opioid crisis. CMS has set an innovative precedent by enabling states to leverage existing funding mechanisms such as the Mechanized Claims Processing and Information Retrieval Systems (90/10), Medicaid Information Technology Architecture (MITA) and the use of Health Information Technology for Economic and Clinical Health (HITECH) Act, enacted as part of the American Recovery and Reinvestment Act of 2009 (Public Law 111-5). This strategy assures that states have greater flexibility in delivering care and prevention protocols to high-risk patients.
CMS hopes states will use this information to improve the technological capacity of state Medicaid agencies, providers and partners to address the opioid crisis and improve the health outcomes for Medicaid beneficiaries.
The key takeaways of the recent CMS guidance to states include:
- Enhanced federal funding opportunities for health information technology can be leveraged by states to support their ongoing efforts to address the opioid crisis.
- Expanded use of MITA funding, which gives a 90 percent federal funds match for the development of a state-run health IT project, and a 75 percent match to maintain these projects.
- HITECH Act funding provides a 90 percent enhanced funding match for state expenditures on activities to promote health information exchange (HIE) and encourage the adoption of certified electronic health record (EHR) technology by certain Medicaid providers until 2021.
- States should discuss with CMS as to whether HITECH funding or MITA funding might be more appropriate for the proposed activities, or a combination of both.
- States can receive enhanced federal funding to build a PDMP or enhance PDMP functionality, including a 90 percent HITECH match for costs related to the design, development, and implementation of PDMPs and connections to PDMPs so long as certain cost controls are met and they help Eligible Providers meet Meaningful Use measures focused on public health reporting and the exchange of public health data.
- States are encouraged to minimize provider burden by integrating PDMP data into EHRs, in a practical way, and to consider complementing PDMPs with provider onboarding and training.
- States are encouraged to consider linking screening data from risk assessment tools such as the Opioid Risk Tool into EHRs and/or HIEs to facilitate targeted case management or to deploy other resources or follow up interventions. Recent research emphasizes the importance of data-driven approaches to address both prevention and treatment of negative opioid outcomes.
- States are reminded that they can deliver covered Medicaid services through telehealth modalities and state plan amendments are only required if a state decides to reimburse for telemedicine services differently than it pays for face-to-face services, visits and consultations. In addition, the guidance emphasizes integrating virtual treatment centers or remote counseling options into care coordination technology to help with addressing provider shortages, particularly in rural areas.
- As many behavioral health providers lack access to EHRs, states may consider reviewing what app-based technologies might be appropriate to consider.
- States might also leverage additional business processes to facilitate shared electronic care plans used to coordinate care between providers, with an emphasis on connecting to substance use disorder treatment providers.
- Some portion of the costs of the systems outside of the Medicaid enterprise that perform a MITA business process may be eligible for an enhanced match as Medicaid may pay for the proportion of costs related to its access and use of such systems. This might include public health systems, such as a birth data registry that could support case management or treatment for pregnant women with opioid use disorder who are at increased risk of delivering a newborn with neonatal abstinence syndrome.
- States might also consider linking care coordination platforms, PDMPs, or electronic care plans with other data sources to support the case management business process in MITA.
- States interested in developing prediction models or deploying advanced analytical approaches to data-driven interventions might also look to complement Medicaid data with data from human services programs.
This effort builds on the November 2017 CMS letter to State Medicaid Directors, Strategies to Address the Opioid Epidemic (SMD 17-003), that provided states with flexibility to address the opioid crisis via demonstration projects under Section 1115 of the Social Security Act.