Lindsey Ferris is a senior advisor at Baltimore-based CRISP Health, a regional health information exchange. She co-authored this article with Matthew Isiogu, senior VP of innovation at Contexture, the umbrella organization for HIEs serving Arizona and Colorado. Lindsey and Matthew are both advisors to the Consortium for State and Regional Interoperability, a collection of the nation’s largest and most robust nonprofit healthcare data organizations.

You have probably heard the conventional wisdom about Medicaid programs: "If you have seen one Medicaid program, you have seen one Medicaid program.” While that’s generally true, it’s also misleading.

Lindsey, who has an undergraduate degree in chemistry, decided early that a lab career wasn’t for her. After five years as an EHR implementation specialist, she pursued a Doctor of Public Health degree with a focus on informatics. One of her many passion projects includes helping states and health information exchanges obtain advanced planning document funding for IT projects supportive of Medicaid priorities.

Meanwhile, Matthew managed the Medicaid budget in Michigan during the Great Recession, and later in Arizona during Medicaid Expansion. With shrinking state budget resources, both states relied on enhanced Medicaid matching dollars to make investments in health IT that would support the transition to value-based payments over time.

Medicaid leaders are making hard decisions during pandemic

Fast forward to today and Medicaid programs across the country are responding in real-time to the COVID-19 pandemic. That means Medicaid program leaders must make hard decisions on how to stretch limited staffing and financial resources.

Matthew witnessed this first-hand at the start of the pandemic. In March 2020, he began attending weekly calls with other Medicaid CFOs to talk about how to manage COVID-19 testing and vaccine reimbursement. During these calls, Medicaid leaders shared what was and wasn’t working in their states; they also brainstormed best practices on topics such a payment parity for telehealth and incentivizing transportation to vaccine sites.

He also discovered during the weekly calls that, while all states have their own Medicaid playbooks, they operate from the same federal rulebook for obtaining funding for new projects and operational technology. Right now, parts of that rulebook are being rewritten for the first time in years. In fact, the rules for what Medicaid will and will not pay for are being defined each day.

For example, Lindsey has been working closely with multiple HIEs and their respective state partners in obtaining funding in support of Medicaid priorities throughout the evolution of the Medicaid Enterprise System funding requirements set by CMS. By keeping a pulse on the requirements as they are refined by CMS, Lindsey brings her advice back to the HIEs she works with to ensure the smoothest process possible while trying to bring consistency across states seeking MES funding for HIE efforts.

Three observations about Medicaid funding for health IT

As a result of our experiences, we’d like to make three observations about Medicaid funding for health IT.

1. There has been a dramatic shift in the way states can fund new and operational HIE efforts under MES–as compared to HITECH – that HIEs and Medicaid programs need to learn together. Relationships may need to be newly formed or strengthened between states and HIEs depending on the Medicaid personnel supporting HITECH versus MES. 

2. The new outcomes-based certification process required under MES to qualify for enhanced operational funding–or more federal dollars for each state dollar spent–is currently in a state of evolution. Personnel at state Medicaid programs can draw on their conversations with CMS state officers and leadership, in addition to their collaborative work with CMS on achieving identified state health IT goals.

3. Medicaid programs and their HIE partners are all figuring out the new rules as they go. Our advice: Seize the opportunity to learn from Medicaid programs and HIEs across the country.

It’s also important to realize that HIEs form the backbone of health IT ecosystems among providers and between providers and the state due to direct investment from Medicaid programs. Most Medicaid programs and HIEs relied heavily on HITECH funding available through federal fiscal year 2021 (which ended September 30, 2021), to encourage adoption of EHRs among providers, connect providers to the HIE, and implement services to improve appropriate electronic access to more complete patient data.

Prepare for the brave new world of MES funding

There is tremendous value in the IT ecosystem created by HIEs to the Medicaid program and providers caring for the beneficiary. If states want to sustain and/or grow their HIE investments made under HITECH, states and HIEs need to be prepared for the brave new world of MES funding.

CMS requires that state reuse and share IT assets acquired by MES, including investments already made in HIEs, in order to:

●      Reduce risk in development, implementation, maintenance, and operations of business processes and systems

●      Lower implementation and operational costs, compared to custom or one-off solutions

●      Accelerate development and implementation timelines

●      Improve the overall quality and maturity of MES

As Medicaid programs determine what comes next for health IT investments with the expiration of HITECH funding, HIEs are the natural partners to build on current programs with MES funding.

Health Data Utilities are the way forward

HIEs are increasingly serving as "health data utilities" and must play a leading role in this discussion. A health data utility is a nonprofit, public-private partnership, which is governed by its community and provides a common source of truth for robust clinical and non-clinical data. This resource can be used by state and other health care system stakeholders to achieve healthier communities through the effective operation of Medicaid and public health programs.

To support Medicaid program and HIE leaders, we offer three pieces of advice:

1. Within a state, Medicaid and HIEs should meet at least monthly to track the latest developments and brainstorm opportunities to partner together.

2. Between states, Medicaid and HIEs should talk at least quarterly to share what they are learning; even if you don’t think you have things to talk about, you probably do.

3. HIEs should build out strategic plans that are explicitly tied to the goals of the Medicaid programs they support; this can also inform strategic planning for the Medicaid program.

To revisit conventional wisdom, a more accurate representation of the Medicaid adage, based on what we have learned, is this: If you’ve seen one Medicaid program, you’ve seen failures others can avoid; you’ve also seen successes others can replicate and expand in their own states.

We’ve learned first hand that collaboration is a must between Medicaid and HIEs, between states, and with CMS, but these entities don’t always speak the same language. Getting help from people like us to translate between them can help everyone get on the same page sooner and get to the same place together.