MMIS and Behavioral
Health Data
Interoperability:
Why Care?
Jeffrey A. Buck, Ph.D.
[email protected]
Incentives for Medicaid – MH
Data Interoperability
General
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trends in state MH financing
Recent changes in Medicaid policy
Health care reform
Health IT initiatives
General Trends in State MH
Financing
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State MH Organization &
Financing
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State-based MH service systems are
transitioning from a model based on grant/
contract financing, and provider needs to a
“Medicaid-centric” one in which health plan
financing models predominate and MH
providers are mainstreamed into the larger
health care system.
Financing Trends
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Medicaid is growing faster than
other sources of public MH
spending
MH Public Payer Shares, 1993-2003
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“The increasing reliance on Medicaid to
fund mental health services has made
the Centers for Medicare and Medicaid
Services the de facto federal mental
health authority.”
Campaign for Mental Health Reform
July, 2005
Medicaid Expenditures for MH/SA
Service Users
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Medicaid Inpatient Days
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Comorbidity of Medicaid MH Users
MH
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service users make up a major portion
of high cost Medicaid enrollees
Jones et al. (2004) - 74% of SMI in
Medicaid had at least one chronic health
problem; 50% had two or more
Another Medicaid study found that of
different pairings of chronic co-morbid
conditions, psychosis was a factor in 5 of
the 7 highest cost pairs
Costly Physical Conditions – 22-64
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Medicaid and State MH Agencies
MH
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agencies administer the public MH
safety net and set data and reporting
standards for specialty MH providers
These agencies increasingly administer part
of the Medicaid program:
In
22 states more than half of state MH agency
community spending is from Medicaid
Important
sectors of the service system fall
outside SMHA overview – e.g., primary care
physicians, nursing homes, and ERs
Recent Changes in Medicaid
Policy
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Reinforce State Medicaid Authority
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“The [Medicaid] agency must not delegate . .
authority to exercise administrative discretion in
the administration or supervision of the plan, or
issue policies, rules, and regulations on program
matters.”
“If other State or local agencies or offices
perform services for the Medicaid agency, they
must not have the authority to change or
disapprove any administrative decision of that
agency, or otherwise substitute their judgment for
that of the Medicaid agency . . .”
Increase provider accountability
Audit
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disallowances – poor documentation
Increased requirements for planning &
provider qualifications
Increased audit activity
Incentives
for state false claims acts
Medicaid Integrity Program ($75 mil for 09 and
beyond) & more $ for Inspector General
Provider compliance program rqrmnts
Promote comm-based services
Clarification
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of availability of HCBS waivers
(1915c) for adults w/MI (new – WI and MT)
New Section 1915i (DRA)
States
can offer HCBS as a state plan optional
benefit (e.g., respite, habilitation, partial hosp)
Doesn’t require “cost neutrality,” imminent
institutionalization, or hosp/NF linkage
Can focus on MI (IA, plus GA & NV proposals)
Individualized, person-centered care plans
Health Care Reform –
Medicaid and MH
Expand
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eligibility based on income,
including SCHIP children and childless adults
Increase Medicaid primary care payment
rates
Reduce disproportionate share payments
Also – Effects of downturn
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Michigan Gov. Jennifer Granholm (D) "has proposed
shaving $40 million from non-Medicaid community
mental health programs...in the new fiscal year,
continuing cuts she imposed by executive order in
May." Meanwhile, "the state Senate passed a
2009-10 budget that would cut $61.8 million from
non-Medicaid mental-health services."
Detroit News 8/11/09
Health IT
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Need for interoperable systems
President's
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New Freedom Commission on
Mental Health
harness
the power of health information
technology and leverage resources through
better federal, state, and local collaborations
Institute
MH/SA
of Medicine quality report
services lag behind general health care
in the use of information technology
Recommends policies/infrastructure to create
linkages among MH/SA patient records and
related data, and standardization of different
reporting/billing requirements
MITA
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“The MITA initiative envisions moving from
traditional MMIS to webbased,patientcentric systems that are interoperable within
and across all levels of government.”
Source: NASCIO
ONC Vision
Implementation
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of IT to allow information
to flow freely between patients, providers
and payers.
By 2015, have 90% of providers and 70%
of hospitals with EHRs with “meaningful
use” of health information.
Status Quo: MH and Medicaid data
incompatibility
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SMHA
and Medicaid data are limited in their
compatibility - differences in data elements
and coding mean that identical service
events cannot be identified with confidence
Many states maintain multiple MH IT
platforms & about half use “legacy” systems
Nearly half use unique service coding
system and DSM IV for dx codes
Less than half have detailed prescription
drug data
MH Specialty Providers
Approximately
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2000 organizations serve
nearly 3 million persons annually
Number one funder is Medicaid
Only about a third of these providers
have some form of EHR, which may or
may not meet federal certification
standards
Generally not eligible for Recovery Act
IT funding
Conclusions
Financing
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trends, Medicaid policy
changes, and health care reform all point
to greater integration of states’ MH
systems into Medicaid
Although a critical part of the public
health safety net, MH agencies and
providers are very far from meeting
expectations for having EHR-based,
interoperable data systems that meet
federal standards
Conclusions
Current
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federal initiatives are unlikely to
address state-level IT issues with
Medicaid MH providers
The extensive dependence and
interaction of this system with the
Medicaid program means that attention
is needed to how it will be brought into
equivalence with other classes of
Medicaid providers
Conclusions
Failure
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to create genuinely interoperable
systems will likely lead to:
Increased
audit vulnerability
Failure to capture legitimate FFP
Provider burden
System duplication and inefficiencies
Failure to realize health IT vision
Conclusions
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MITA offers a solution!
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