Any provider attesting to receive an EHR incentive payment for either the Medicare or Medicaid EHR Incentive Program potentially can be subject to an audit. Here’s what you need to know to make sure you’re prepared:
- Save the electronic or paper documentation that supports your attestation.
- Save the documentation that supports the values you entered in the Attestation Module for Clinical Quality Measures (CQMs).
- Hospitals should also maintain documentation that supports their payment calculations.
If you are selected for an audit, the documentation will be used to validate that the provider accurately attested and submitted CQMs, as well as to verify that the incentive payment was accurate. If a provider is found to not be eligible for an EHR incentive payment, the payment will be recouped. The Centers for Medicare & Medicaid Services (CMS) has an appeals process for eligible professionals, eligible hospitals, and critical access hospitals that participate in the Medicare EHR Incentive Program.
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Data recently released by the Centers for Medicare & Medicaid Services (CMS) reveals the objectives of stage 1 meaningful use most commonly deferred by qualifying participants. Though it was acceptable to defer five “menu set” objectives during stage 1, most are mandatory for stage 2 which kicks-off in 2014 for most physicians.
Below, stage 1 menu set items listed in descending order from most to least deferred.
- Provide A Summary Care Record: 84%
- Send Patient Reminders: 80%
- Submit Electronic Syndromic Surveillance Data: 68%
- Provide Patients Timely Electronic Access: 66%
- Perform Medication Reconciliation: 55%
- Provide Patient Education Resources: 50%
- Incorporate Clinical Lab-Test Results: 36%
- Generate Lists of Patients: 25%
- Submit Electronic Data To Immunization Registries: 21%
- Implement Drug Formulary Checks: 15%
Source: CMS Office of E-Health Standards and Services
The Office of the Inspector General (OIG) will undertake a review of American Recovery and Reinvestment Act (ARRA) which will include probes into the EHR stimulus program to ensure that people attested to meaningful use properly.
In its latest plan, OIG states it will look at incentive payments made by the Centers for Medicare & Medicaid Services CMS made beginning in 2011 to identify payments to providers that should not have received incentive payments – those that did not meet the meaningful use criteria. The OIG will also assess CMS’s plans to oversee incentive payments for the duration of the program and actions taken to remedy erroneous incentive payments.
If you’re part of a meaningful use audit or have information on what’s involved, please let us know. HMS Healthcare Management Solutions would love to learn from those who have firsthand experience with the process.
Trust is key in any doctor-patient relationship. Patients trust their doctors to keep their health information private and secure. To that end, protecting a patients privacy and securing their health information is a core requirement for the Medicare and Medicaid Electronic Health Record (EHR) Program. Below are some tips to meet the security requirements of patient health information and ensure patient trust.
- Issue unique user name and passwords to everyone who will use the EHR in your practice to prevent unauthorized and inappropriate access
- Associate access levels with specific roles, if possible
- Use encryption technology to protect patient health information from being read by an unauthorized party
- Plan a backup of your system to keep information available when and where it is needed
- Recover systems in the even of an incident such as a fire, cyber-attack or natural disaster
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Looking to attest for Meaningful Use? Below are some important dates to mark on your calendars.
- October 3, 2012: October 3 was the last date to begin the 90-day reporting period to earn an $18,000 EHR incentive payment for 2012, and to be eligible for the maximum total of $44,000.
- January 1, 2013: First day of the 365-day reporting period for 2013 for providers who earned their first incentive payment in 2011 or 2012.
- February 28, 2013: Last date to register and to attest for the 2012 EHR incentive.
- October 3, 2013: The last day to start the 90-day reporting period and earn a $15,000 2013 incentive.
- October 1, 2014: The last date to submit a successful meaningful use attestation and avoid the 2015 payment adjustment.
When adopting an EHR, it’s important to identify any gaps in how your practice fulfills its responsibilities for both the HIPAA Privacy Rule and other applicable laws. Privacy is the focus of the 4-step process which complements the security risk analysis process emphasized in the 10-step plan for meeting Meaningful Use.
4-Step Privacy Process:
- HIPAA Privacy Rule: Read about and become familiar with HIPAA Privacy Rule requirements.
- State Privacy Laws: In many states, state agencies or professional associations have prepared an analysis of the interaction between state privacy law and the HIPAA Privacy Rule. Find out if such an analysis is available in your state.
- Federal & State Privacy Requirements: Review your practices’ adherence to federal and state privacy requirements. Assess and address any compliance gaps.
- Patient Privacy Concerns: Anticipate and address privacy concerns patients may have as their health information goes digital.
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Although Stage 2 Meaningful Use requirements don’t become effective until 2014, the Final Rule for Stage 2 contains some changes which will go into effect in 2013, including:
- It will no longer be required to conduct a test of the EHR’s capacity to exchange clinical information. Instead, Stage 2 measures will require an ongoing exchange of information.
- Any physician who located more than 10 miles from a pharmacy accepting electronic prescriptions will be excluded from the ePrescribing requirement.
In addition, these measures required in 2014, can be adapted in 2013 at a physician’s discretion:
- Reporting in the Vital Signs measure will separate height and weight from blood pressure.
- Minimum ages for reporting the blood pressure, as well as height and weight have also been amended: blood pressure reporting will be required for patients age 3 and above while height and weight will now be required for all patients.
- An alternate calculation for CPOE will limit the denominator to medication orders created by the EP during the EHR reporting period.