Meaningful Use Mock Audit Encore Event
By Jim Tate, EMR Advocate
Meaningful Use Audit Expert
Twitter: @JimTate, eMail: audits@emradvocate.com
CMS EHR Incentives 2.0
A couple of weeks ago I presented a webinar discussing the importance of mock audits for Eligible Hospitals (EHs) and Critical Access Hospitals (CAHs). I’ve gotten a great number of emails and inquiries asking if I can repeat the event and will do an encore of the webinar on September 18, at 1 pm Eastern. You can register here.
I’ve written extensively about how the Centers for Medicare & Medicaid Services (CMS) will conduct EHR incentive audits on at least five percent of the program participants for each stage of meaningful use. While a small portion of these audits will be random, the rest will be triggered by red flags based on attestation data and lack of adequate documentation of meaningful use measures.
A couple of interesting questions were posed during the event which I’ve answered below:
Q: Can an Eligible Professional initiate the secure electronic message process and count it toward the numerator if they receive a message back from the patient?
A: Secure Electronic Messages is a core measure for Stage 2 beginning in 2014. The measure is defined as “A secure message was sent using the electronic messaging function of CEHRT by more than 5 percent of unique patients (or their authorized representatives) seen by the EP during the EHR reporting period.” Nowhere in the relevant documents is the requirement that the communication must begin with the patient. I am aware of no guidance that says that a patient reply would not be as meaningful use for the purposes of the measure.
Relevant document links:
- Use Secure Electronic Messaging – CMS
- Use Secure Electronic Messaging – Health IT
Q: What are you hearing about audits for Meaningful Use Stage 2?
A: Stage 2, due to the variation from the Stage 1 requirements and thresholds, requires different documentation. However, I would expect the volume of audits and the actual process to very similar to what we have been seeing for the past several years.Q: As it relates to EP/EH/CAH Stage 2: View-Download and Transmit (Core measure #7 for EPs and Core measure #6 for hospitals). How would MU auditors handle this? Does the patient’s ability to transmit their health information need to be in place on day 1 of the attestation period? Or can the ability be added during the attestation period as long as 5% of the patients seen during the reporting period actually completes one action out of the three actions, (V or D or T) to meet the criteria? What type of supporting documents should be saved in case of an audit?A: The View, Download and Transmit core requirement is a percentage threshold and the numerators and denominators would be generated by the certified technology. I would expect that during an audit the documentation requirements would be similar to the other percentage based measures. Since the acceptable threshold is an average over the reporting period, it would be possible for no numerator data be recorded for periods of time as long as the final percentage was met.
If you attended the July webinar I hope you’ll join me again in September as I update the status of MU audits. And if you missed the July event, please attend if you’re interested in learning more about the mock audit process. Here’s the link with the details and registration form. Have questions? Email me at: audits@emradvocate.com
Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. His unique combination of skills has brought successful outcomes to hospitals at risk of having their CMS EHR incentives recouped. He led the first appeal challenge in the nation for a client hospital that had received a negative audit determination. That appeal was decided in favor of the hospital. He has also been successful in leading the effort to reverse a failed appeal, even after the hospital had received notification of the failure with the statement, “This decision is final and not subject to further appeal”. That “final” decision was reversed in less than a week. If you are a hospital with questions or concerns about the meaningful use audit process, contact him at: audits@emradvocate.com. This post was original published on MeaningfulUseAudits.com.