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Dr Berger’s Entrance
Hello … I’m Dr. John Berger.
I would like to share with you a recent Meaningful Use experience that gave me a little heartburn …
We have a small clinic … only 10 physicians.
About a month ago, we received notice that one of our physicians
would be audited by CMS regarding their 2011 Meaningful
Use Attestation.
No worries.
We use a certified EHR product. Our vendor took
care of us.
Dr Berger Comments 3
What we found out was ….
… all was not so simple as we thought.
Dr Berger Comments 3
Let me share with you the
conversations we had along the way.
Dr Berger animation
Here’s the call from the auditor
Hello, Dr. Berger. We’ll be auditing your 2011
Meaningful Use attestation, for which you received
$18,000.
Please provide documentation proving that you fulfilled all criteria, were using Certified EHR Technology, and were an eligible, non-hospital-based
Medicare provider during the 2011 reporting period.
So I called our Office manager to start the process.
Jackie, please arrange
everything the auditor
needs.
Introduction – Jackie Ford, Requirements Manager
I’ll start running the reports right away.
We have upgraded our EHR since 2011, so we
should be in good shape.
That’s when the trouble began
I got a call from our EHR vendor,
after Jackie asked them to help out.
Hello, Dr. Berger.
You realize that we can’t really re-run 2011 reports, right?
For one thing, you are now on the 2013 version of our software, and
those reports have changed.
… and even if we could do exactly the same reports, the patient data
has changed, too.
For example, there’s no way we could identify whether “smoking
status” was updated for any patient in 2011 … if you’ve seen that
patient since then and updated their records. We only have current
values.
That was a shock. But it got worse.
It seems our EHR creates reports against 16 percentage based
measures. But …
There are another nine items the auditors want to
see and there are no reports at all from the EHR
on those.
They want proof that we followed a clinical decision
support rule, integrated with the hospital and tested the
EHR’s ability to do electronic syndromic surveillance. We don’t have reports for those.
Next, I got a call from our
IT consultant.
Introduction – Ron Holmes, Quality Manager
Uhhh … Dr. Berger?
The auditors want a copy of a HIPAA privacy and security
review.
But the EHR vendor told us that if we were using their Certified Product, we were
covered for HIPAA
Introduction – Ron Holmes, Quality Manager
Now the auditor says that is not enough. We need a copy of the “Privacy and Security
Review” from 2011.
… and we didn’t do anything like that.
Introduction – Ron Holmes, Quality Manager
I’m really sorry.
And, one more thing …
Introduction – Ron Holmes, Quality Manager
Remember how we were trying to save some money in 2011?
And we decided not to by the extra Lab module? Well … we found out that the Lab module
had to be part of the EHR in order for us to really be
“Certified”
Introduction – Ron Holmes, Quality Manager
So, even though we bought it in 2012, we were not certified in 2011, even though we thought
we were.
Introduction – Ron Holmes, Quality Manager
We thought we were good. We bought the Certified product after all … just not all of it.
And the auditor says that’s not good enough.
I’m really sorry. It is a great EHR, though.
So why didn’t
someone tell us???
Introduction – Ron Holmes, Quality Manager
Thing is … he’s right.
It is a great EHR. But I counted on them for Meaningful Use, and that just didn’t work
out.
Introduction – Ron Holmes, Quality Manager
In the end, the auditors identified seven
deficiencies , any one of which would have disallowed our 2011
attestation.
Introduction – Ron Holmes, Quality Manager
So I had to write a check to CMS to repay the $18k
stimulus money I received in 2011.
Talk about disappointment. I was hopping mad.
Introduction – Ron Holmes, Quality Manager
These regulations are complicated.
Someone should have told me.
Introduction – Ron Holmes, Quality Manager
Since then, we’ve taken some corrective actions so our other providers don’t
get hurt.
Take a look at these “Lessons Learned”
Lesson 1: You can’t change the past!
Meaningful Use Audits are against a prior year, and you can’t create documentation you didn’t save in
the first place.
Lesson 2: Your EHR Vendor cannot do it all
You have to document a number of actions, decisions and tests that don’t come from your
EHR’s reporting tools.
Lesson 3: The regulations are not simple
Find some good expertise, and ask questions frequently. Get some formal training.
Lesson 4: Attestation and payment are not the “End Game”
Audits can occur for several years after you’ve received your money, and you need to retain
documentation of each single year. Just like income taxes.
Dr Berger’s Wrap up 3
So that’s the story of our CMS Audit, and what we learned.
Dr Berger’s Wrap up 3
Since then, our EHR vendor has made some really positive changes.
They now provide us something called the
Meaningful Use Monitor
And it gives us the formal expertise and tools to withstand an audit.
I highly recommend you take a look at it, so you don’t have the bad experience we
did.
Dr Berger’s Wrap up 3
Be sure to check out
Meaningful Use
Monitor!
Jay Fisher414-640-2817
Chris Coleman414-640-2817
Contacts
http://MeaningfulUseMonitor.com
