Policy & Regulation News

Pew Recommends CMS Reconsider EHR Advance Care Plan Updates

“Clinicians must be able to find an advance care plans in the EHR, and these documents must follow patients as they move from one care setting to another."

By Jacqueline DiChiara

- Making decisions in life is not always easy. End-of-life care decisions are no exception.

meaningful use final stage 3 rule EHRs

The Centers for Medicare & Medicaid Services (CMS) recently proposed numerous revisions to the physician payment system under MACRA. The Pew Charitable Trusts (Pew) expressed its concern last month regarding the lack of end-of-life conversations and the essential need for palliative care initiatives.

Pew urged CMS to ensure the Merit-Based Incentive Payment System (MIPS) bolsters the transmission of advance care plans across care settings. This is an imperative aspect of the overall shared-decision making process, Pew said.

"Access to palliative care can increase patient satisfaction, improve clinical outcomes, and reduce costs of care for patients enrolled in palliative care services,” wrote Lee Goldberg, Pew’s Director of the Improving End-of-Life Care Project, in a November letter to CMS.

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  • “Unfortunately, our health system does not currently have an effective and consistent strategy to provide supportive care to this population.”

    CMS “needs to develop models that expand payment to include the full interdisciplinary care team. As CMS is considering models of care that would be appropriate for physician-focused payment models, we encourage the agency to include models that offer a robust palliative care component.”

    Pew submits new commentary on CMS’s EHR incentive program

    Last Tuesday, Pew submitted additional commentary on the Electronic Health Record (EHR) Incentive Program’s Stage 3 final regulation issued by CMS.

    Pew supported recent updates to the meaningful use program and EHR certification criteria. These revisions will help healthcare providers better store, share, and access advance care plans across settings, Pew asserted.

    “Terminal illness presents profound challenges — for the person who has an illness, for their relatives, and for their caregivers and members of their community. Ensuring that patients have articulated the kind of care they want (and do not want) can help address these challenges, particularly at the end of life when many people cannot speak for themselves,” wrote Goldberg to the Department of Health and Human Services (HHS) and CMS.

    Goldberg supported the new updates to the Meaningful Use program and EHR certification criteria to advance the capture of advance care plans in EHRs.

    “Creating an environment where patients and providers can easily store, share, and access advance care plans across settings and among providers and family members is essential for providing patient-centered care that aligns with patient goals, values, and preferences.”

    Goldberg additionally said the ability to store an advance care plan is only a first step for future action.

    “Clinicians must be able to find an advance care plans in the EHR, and these documents must follow patients as they move from one care setting to another. Only then will health information technology make a major contribution toward helping providers honor the goals and preferences of patients.”

    Pew’s recommendations on EHR incentives

    Here are 3 selected highlights from Pew’s suggestions to CMS for how to best improve access to advance care plans in EHRs:

    • The final Stage 3 rule did not have a provision for EHRs to properly label all such documents as advance care plans, noting that the Office of the National Coordinator (ONC) preferred to keep the definitions of patient-generated data (one of the two places advance care plans are found in EHRs) “as broad as possible.” We urge ONC to revisit this issue at some point in the future as progress is made in the development of more interoperable EHR systems.
    • [We] urge CMS as part of future rulemaking to explore regulatory or administrative options that address the goal of ensuring that clinicians are aware of a patient’s advance care plans in the EHR.
    • [We] urge ONC to review how advance care plans can be incorporated into the CCDS and support new document structures in the C-CDA to make advance care plans accessible across settings.