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Meaningful Use Audits
Taino Consultants Inc.Dr. Jose I. Delgado
Background
• What is meaningful Use
• Requirements
• Stages, Incentive and Fines
• Audits
• Reminders and Important details
• Recommendations
What is Meaningful Use
• Established by the Health Information Technology for Economic and Clinical Health (HITECH) Act of 2009
• Defines the use of electronic health records (EHR)
• Requirement before an organization may request payments under the EHR incentive program
Requirements
• Eligible Professional
– Providers eligible for incentives
• Certified EHR
• Meaningful Use
– Three Stages
• Specific Program
– Medicare
– Medicaid
Eligible Providers
Medicare• Doctor of medicine
• Doctor of osteopathy
• Doctor of dental surgery
• Doctor of dental medicine
• Doctor of podiatric medicine
• Doctor of optometry
• Chiropractor
Medicaid• Physicians
• Dentists
• Certified nurse midwives
• Nurse practitioners
• Physicians assistants (in rural
health clinic or FQHC led by a
physician assistant)
Certified Electronic Health Record
• EHR that is certified specifically for the EHR Incentive Programs
• Must have met CMS and the Office of the National Coordinator for Health Information Technology (ONC) established standards
• Must be on the Certified Health IT Product List (CHPL)
– http://healthit.hhs.gov/chpl
Meaningful Use StagesStage 1 Stage 2 Stage 3
EHR Adoption and Data Gathering
Enhances care coordination and exchange of patient information
Improves healthcare outcomes**Under development by ONC
Using the information to track
key clinical conditions
Disease management, clinical
decision support
Focusing on decision support
for national high priority
conditions
Communicating captured
information for care
coordination purposes
Quality measurement Achieving improvements in
quality, safety and efficiency
Reporting of clinical quality
measures and public health
information
Support 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 MedicaidMedicare Medicaid
Starts in calendar year 2011 Starts in calendar year 2011
Up to $44,000 over five years Up to $63,750 over six years
Maximum 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 EHR
For maximum reimbursement 1st year cost no later than 2012
1st yr cost no later than 2016
No payments made after 2015 No payments made after 2021 or more than 5 years
Penalties 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 agency’s 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 Audits
• Pre-payment • Post Payment
Notes: 1. Take audits seriously.2. Discrepancy in attestation information and
information submitted for the audit may result in failure.
3. Failure to provide support documentation on any area may result in 100% re-payment of monies received.
What to expect1. Electronic letter from audit company from a
CMS e-mail address;
– Letter will be addressed to email address provided during registration
2. Attachment with a request for support documentation
3. About 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 vendor’s 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 Measures– Measures must display vendor’s 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.
Reminders
• Information 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.
Recommendation
• Be proactive
• Develop a “Book of Evidence” for every entity/Provider receiving incentive money
• Contact us if you need assistance with any of the following:– Development of Book of Evidence
– Security Risk Assessments
– Security Management Plans
– HITECH/Meaningful Use audit response
