The SNF Final Rule indicates that interoperability of data will be important. What do we need to do about this issue?
The Centers for Medicare & Medicaid Services has not yet implemented specific information about how SNFs will be required to upgrade computer systems to be more interoperable.
In the Skilled Nursing Facility Final Rule of 2015, CMS acknowledges that SNFs are not eligible for the Medicare and Medicaid EHR Incentive Programs. In other words, there is no government financial assistance to implement new IT systems in skilled nursing facilities.
They do, however, identify that adoption and use of health information exchange and health IT tools will be essential as the [SNF] setting seeks to improve quality and lower costs through initiatives such as VBP (Value Based Purchasing). In addition, CMS refers skilled nursing facilities to several government documents, including a “roadmap,” that discusses barriers to interoperability.
Reading this may help you to understand the vision of CMS. The other document that may be helpful is the 2016 Interoperability Standards Advisory report. It lists the best available standards and implementation specifications.
Some things to think about at this point: Many facilities are looking at implementing electronic health record systems. The health information exchanges go far beyond your individual facility documentation system. CMS in the SNF PPS Final Rule does encourage a facility to utilize these standards and certified health information technology.
From a practical standpoint, make sure that as you are discussing EHR with vendors, you are questioning their understanding of the CMS “roadmap” and the best available standards.