If you are among the millions of eligible professionals participating in the government’s Electronic Health Record (EHR) Incentive Program, you likely have invested significant time and effort into satisfying the program’s many requirements. Don’t let that investment go to waste by failing to keep sufficient documentation of your eligibility and performance under the program. The Centers for Medicare & Medicaid Services (CMS) has quietly started auditing providers who received meaningful use incentive payments through the Medicare program as required by law; states are arranging their own audits of Medicaid providers who receive incentive payments. Early reports are that an estimated three to five percent of participants in the program are being audited.
<!–more–>Here’s how to make sure your practice is audit-ready:
Retain all supporting documentation related to your attestation of EHR readiness, including a copy of the attestation signed by the eligible professional who submitted it..A post-payment audit is likely to also request:
<li>Documentation from the Office of the National Coordinator for Health Information Technology (ONCHIT) showing that you used a certified EHR system for meaningful use attestation; and</li>
<li>Documentation that you completed the attestation for the core set of meaningful use criteria and the required number of menu set of objectives for meaningful use. In addition to evidence in support of each measure to which you attest, be ready to back up any exclusions that you claim.</li>
Retain copies of screen shots and confirmations from any registries, labs and other providers to whom you sent information electronically in meeting meaningful use requirements.
Anticipate the unanticipated. The government’s record-keeping instructions are nebulous at best (CMS admits: “…it is not possible to include an all-inclusive list of supporting documents”); plan to retain all reports related to the incentive program for six years.
If you are seeking incentive bonuses through the Medicaid program, make sure you can prove that you met the qualifying percentage of Medicaid volume needed (30 percent for adult providers; 20 percent for pediatrics).
Be prepared to dig deeper. You might also be asked to support your performance in:
<li>Protection of Electronic Health Information – Save written documentation and results of the security risk analysis of certified EHR technology you were required to complete before the end of reporting period. Be sure to note the results of the analysis.</li>
<li>Submission of Immunization Registries Data, Syndromic Surveillance Data, and Reportable Lab Results to Public Health Agencies – Compile screenshots from your EHR system or other documentation of a test submission (successful or not) to a registry or public health agency. You may substitute a confirmation letter or email from the registry or public health agency that includes the submission date, name of parties involved, and whether the test was successful in addition to a confirmation of the receipt (or its failure) of the submitted data.</li>
<li>Functionality of Drug-Drug/Drug-Allergy Interaction Checks and Clinical Decision Support – This includes documentation that the functionalities were available, enabled, and active in the system for the duration of the EHR reporting period.</li>
<li>Drug Formulary Checks – Proof that the functionality was available, enabled, and active in the system for the duration of the EHR reporting period.</li>
<li>Exchange of Clinical Information Electronically – Screenshots from the EHR system or other evidence documenting a test exchange of key clinical information (successful or not) with another provider of care. A letter or email from the receiving provider confirming the exchange may suffice but should include the date of the exchange, name of providers, and whether the test was successful.</li>
A CMS contractor, the <a href=”http://e2.ma/click/kmgax/4d3x6i/g7h6lb”>Garden City, N.Y.–based accounting firm of Figliozzi & Company</a>, has already started sending letters to health care providers who received incentive checks, asking them to furnish documentation to support their meaningful use attestations. If you are selected for audit as a Medicare participant, the initial contact is expected to be from a CMS email address. Because states are choosing their own vendors to perform audits, be sure to verify details with your state’s Medicaid agency before handing over documents to auditors involved with the Medicaid program.
In addition to post-payment audits, the government has built in pre-payment edit checks to its EHR Incentive Program reporting and attestation’s process to identify inaccuracies in eligibility, reporting, and incentive payments. Regardless of when an inaccuracy is discovered, the government will attempt to recoup payments deemed inappropriate. Should you disagree with the decision, there is an appeals process in place for the federal government as well as a mandated process for each state conducting Medicare incentive post-payment audits. View a brief overview of the audit and appeals process at <a href=”http://e2.ma/click/kmgax/4d3x6i/wzi6lb”>this link</a>.
<h5>About the Author</h5>
<strong>Elizabeth Woodcock</strong> is a professional speaker, trainer and author specializing in medical practice management. Elizabeth has focused on medical practice operations and revenue cycle management for more than 20 years. Combining innovation and analysis to teach practice operations, she has delivered presentations at regional and national conferences to more than 150,000 physicians and managers. In addition to her popular email newsletters, she has authored 12 best-selling practice management books, and published dozens of articles in national healthcare management journals.
Elizabeth is a Fellow in the American College of Medical Practice Executives and a Certified Professional Coder. In addition to a Bachelor of Arts degree from , completed a Master of Business Administration in healthcare management from The Wharton School of Business of the University of Pennsylvania.
You could receive a letter like this very soon:
“This letter is to inform you that your organization has been selected by the Centers for Medicare & Medicaid Services (CMS) for an audit of your facility’s meaningful use of certified EHR technology for the attestation period. Attached to this letter is an information request list. Be aware that this list may not be all-inclusive and that we may request additional information necessary to complete the audit.”
Head spinning? Heart racing? Palms sweaty? Take a deep breath and contact tnREC.Read More »
Tennessee healthcare providers streamline the process of communicating patient information
Nashville, Tenn. (January 22, 2014) The Tennessee Office of eHealths’ Health eShare Direct Project has been the driving force in assisting more than 4,000 healthcare professionals in Tennessee to embrace Direct Technology. Direct facilitates secure health information exchange (HIE) through the electronic transmission of patient health information closing the gap in healthcare communication by painting a full picture of a patient’s healthcare status for all providers involved in the continuum of care.
According to David C. Kibbe, MD MBA, senior advisor to the American Academy of Family Physicians (AAFP) , DirectTrust cofounder and CEO, the adoption of Direct messaging and creation of meaningful use cases in Tennessee is among the most rapid he has seen. In fact, according to the most recent data provided by DirectTrust to the Office of the National Coordinator for Health Information Technology (ONC), Tennessee now represents nearly 5 percent of all Direct active accounts established nationally.
Direct was initially piloted among the healthcare communities in Chattanooga, Memphis and Hickman County this past spring. Under contract with the Tennessee Office of eHealth Initiatives (OeHI), Qsource utilized the lessons learned from the pilot program to expand Direct statewide, beginning in June of this past year.
As an incentive for participation, OeHI provided incentives for up to 4,000 participants of $500 per Direct user account. Qsource was charged with distributing those funds before January 31, 2013. The goal was reached six weeks early.
“As the sponsor of the Direct Project in Tennessee, watching it grow and succeed has been very satisfying and it has truly expanded health information exchange in Tennessee. I am grateful for the opportunity to have worked side by side with Qsource who helped make this project such a success,” said George Beckett, Health IT Coordinator for OeHI.
In Chattanooga the Southeast Tennessee Area Agency on Aging and Disability is participating in the Community-based Care Transitions Program (CCTP). The agency is responsible for connecting the agency’s high-risk clients who are discharged from the hospital inpatient care settings with the community care, rehabilitation and ancillary services that they need to recuperate, recover and avoid costly hospital readmissions. Once enrolled in the pilot project, the agency began receiving patient discharge notifications and relevant patient information from clinical charts almost instantaneously with the use of Direct technology. The agency staff is able to reach out to patients, usually within hours of their discharge. In nine short months, this community has sent more than 2,000 Direct messages.
Healthstar Physicians, PC is a multi-specialty physician group with a support staff of more than 450 that serves 11 locations in four counties in East TN. Direct Technology is assisting this large organization by allowing it to securely exchange patient health information needed between multiple transitions of care within their own organization. Since implementing Direct in October 2013, the organization has sent over 1,500 messages to support patient care.
Direct technology is also a protocol used to achieve two of the measures for information exchange required for providers and hospitals seeking to maximize incentives for Stage 2 of the EHR Incentive Program. While the funding for Direct is no longer available, the value of Direct continues to grow, with more than 13,500 messages sent in Tennessee alone.
Beckett further stated, “I would like to take a moment to thank the Qsource team for their hard work and dedication on the Direct Project. With their dedicated assistance and leadership we were able to achieve our goals.”
For more information about the Health eShare Direct Project visit www.HealtheShareTN.com. To learn how Qsource can help you evaluate Direct for your healthcare organization, call (866) 514-8595.
About the Office of eHealth
The mission of the Tennessee Office of eHealth Initiatives (OeHI) is to facilitate improvements in Tennessee’s health care quality, safety, transparency, efficiency, and cost effectiveness through statewide adoption and use of electronic health records (EHR) and health information exchange (HIE). OeHI received grant funding from the American Recovery and Reinvestment Act of 2009 (ARRA) to support this Direct Project and other projects to implement secure health information exchange. Through these stimulus funds, ARRA enables Tennessee the opportunity to advance the secure exchange of health information and to expand the adoption and Meaningful Use of EHRs and HIE. For more information, please visit http://www.tn.gov/ehealth/.
Qsource is a nonprofit, 501(c)(3) healthcare quality improvement and information technology consultancy headquartered in Tennessee since 1973. Qsource provides a wide range of expert services to assist organizations and providers in improving healthcare quality and delivery with better patient outcomes and cost savings. Qsource consulting services are offered through our Divisions/Subsidiaries/Affiliates, Tools & Resources, and associates staffing offices in Memphis, Nashville and Knoxville, Tenn., as well as Little Rock, Ark. For more information, please visit www.qsource.org.
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