HIT as a Change in Scope

On October 20^th, 2008 Shasta Community Health Center, a Federal 330 funded Community Health Center, was formally notified by Audits and Investigations Unit of the Department of Health Care Services, State of California, that Shasta CHC had been approved for its scope change request as submitted with the precipitating event being Shasta’s implementation of an EMR. With the help of the California Primary Care Association (CPCA), and financial consultants from BKD, Shasta CHC had submitted a request for a Scope Change and FQHC rate adjustment based on its implementation of an Electronic Medical Records (EMR) system in fiscal/calendar year 2007. In accordance with the State of California’s approved Scope Change policy, Shasta CHC identified the implementation of the EMR as a “scope changing event” that met the federal guidance that the implementation of EMR was an event that changed the “type, intensity, duration and/or amount of FQHC services provided by Shasta.”  To underscore this issue the CPCA had earlier commissioned a research article that used Shasta as a “case study” in identifying the ways in which its implementation met the federal guidance and the requirements of the State of California for approving scope changes. Making the case for the adoption of EMR as a “scope changing event” was facilitated by California statute describing this process.  Although under California statute, the “scope changing event” must directly impact the “type, intensity, duration and/or amount of FQHC services”, statutory language does provide a list of events that could qualify including; 1) a change in types of services due to a change in applicable technology and medical practice utilized by the center or clinic and 2) changes in operating costs attributable to capital expenditures including new or expanded service facilities, regulatory compliance, or changes in technology or medical practices at the center or clinic.  Other states have similar provisions in their state laws.

 

In the case study, SCHC needed to demonstrate that the impact of E.H.R. adoption was not purely administrative, but had a direct impact on patient services. The case study demonstrated that, for example, more preventative services were being provided and that the Intensity & Amount of services increased as more information was available to the clinician and more services were provided to the patient at each visit, particularly for those who had chronic and/or other complex medical conditions that would have normally required more visits in a paper based system. The State also recognized that there were potential downstream cost-savings from the use of EMR type technology and from a policy standpoint, as established by the Governor, there was and is a drive to encourage a greater use of Health Information Technology to help improve the health of patients and the cost-effectiveness of the services that are delivered. In summary, based on the results of this case study and in keeping with State policy direction regarding Health Information Technology, Shasta’s scope change application was approved helping to set the path for other FQHCs in California in particular and hopefully FQHCs throughout the United States in general, to be able to find a way to afford the large investment that it takes to make this conversion for the benefit of the patients that we serve in our communities.