Meaningful Use Audits
Meaningful Use AuditsTaino Consultants Inc.Dr. Jose I. DelgadoBackgroundWhat is meaningful UseRequirementsStages, Incentive and FinesAuditsReminders and Important detailsRecommendationsWhat is Meaningful UseEstablished by the Health Information Technology for Economic and Clinical Health (HITECH) Act of 2009Defines the use of electronic health records (EHR)Requirement before an organization may request payments under the EHR incentive programRequirementsEligible ProfessionalProviders eligible for incentivesCertified EHRMeaningful UseThree StagesSpecific ProgramMedicareMedicaid
Eligible ProvidersMedicare Doctor of medicineDoctor of osteopathy Doctor of dental surgeryDoctor of dental medicine Doctor of podiatric medicineDoctor of optometryChiropractorMedicaid PhysiciansDentistsCertified nurse midwivesNurse practitionersPhysicians assistants (in rural health clinic or FQHC led by a physician assistant)
Certified Electronic Health RecordEHR that is certified specifically for the EHR Incentive ProgramsMust have met CMS and the Office of the National Coordinator for Health Information Technology (ONC) established standardsMust be on the Certified Health IT Product List (CHPL)http://healthit.hhs.gov/chplMeaningful Use StagesStage 1Stage 2Stage 3EHR Adoption and Data GatheringEnhances care coordination and exchange of patient informationImproves healthcare outcomes**Under development by ONCUsing the information to track key clinical conditionsDisease management, clinical decision support
Focusing on decision support for national high priority conditions
Communicating captured information for care coordination purposesQuality measurement
Achieving improvements in quality, safety and efficiency
Reporting of clinical quality measures and public health informationSupport for patient access to their health information
Access to comprehensive patient data
Capturing health information in a coded format Bi-directional communication with public health agencies
Patient access to self-management tools
*Not all Inclusive.Medicare vs MedicaidMedicareMedicaidStarts in calendar year 2011Starts in calendar year 2011Up to $44,000 over five yearsUp to $63,750 over six yearsMaximum of $18,000 on the first year if EP bills Medicare $24,000 or more.based on up to 85% of state-calculated global average costs for EHRFor maximum reimbursement 1st year cost no later than 20121st yr cost no later than 2016No payments made after 2015No payments made after 2021 or more than 5 yearsPenalties start in 2015 (1%) and increases by 1% every year until 2019 with a max of 5%.No Medicaid penalty for failure to demonstrate Meaningful Use Audits"Meaningful Use audit is a matter of when you will get audited, not whether. - Anantachai (Tony) Panjamapirom, PhD, Senior Consultant at The Advisory Board Company The Centers for Medicare and Medicaid Services has awarded Figliozzi and Co., of Garden City, N.Y., a contract to audit payments and compliance with the agencys EHR Incentive Program.Contract Award Date: April 16, 2012 Dually-eligible providers will not be audited twice (although a hospital could get audited by the State for eligibility and hospital calculation, and then audited by the CMS contractor for Meaningful Use).
Types of AuditsPre-payment Post Payment
Notes: Take audits seriously.Discrepancy in attestation information and information submitted for the audit may result in failure.Failure to provide support documentation on any area may result in 100% re-payment of monies received.
What to expectElectronic letter from audit company from a CMS e-mail address;Letter will be addressed to email address provided during registration Attachment with a request for support documentationAbout four weeks to submit documentation
Key Items to keep in mind Proof of use Certified EHR. Need Copy of licensing agreement with the vendor or invoices for the period.List of office or outpatient facility where Provider sees patients. Identify if records are kept outside of EHR. Report showing compliance with specific Core Measures must display vendors logo or step by step screenshots which demonstrate that the report was generated by the EHR.Key Items to Keep In Mind (continuation)Core measure 15 Provide Proof that a security risk analysis was performed prior to the end of the reporting period.If deficiencies were noted provide implementation plan with completion dates.Menu Set Objective MeasuresMeasures must display vendors logo or step by step screenshots which demonstrate that the report was generated by the EHR.
Note: Verify that information used to respond to the audit matches the numbers submitted on the CMS attestation form.
RemindersInformation used to respond to the audit must match the numbers submitted on the CMS attestation form.Keep all information regarding Meaningful Use Attestation for a minimum period of 6 years.
RecommendationBe proactiveDevelop a Book of Evidence for every entity/Provider receiving incentive moneyContact us if you need assistance with any of the following:Development of Book of EvidenceSecurity Risk AssessmentsSecurity Management PlansHITECH/Meaningful Use audit responseTaino Consultants IncE-mail: DrDelgado@TainoConsultants.comwww.tainoconsultants.comTel 904-794-7830