MU Attestation and Public Health Measures
by Jim Tate
Twitter: @JimTate
“The windy beach, far from the twisted reach of crazy sorrow” as Dylan proclaimed. Even here, beneath the diamond skies of Coral Bay on St. John Island, I am not beyond emails informing me of the latest developments pertinent to CMS EHR Incentive audits.
In between snorkel trips to Trunk Bay and Salt Pond Beach I find disturbing emails lurking through my inbox. Of course, there are the standard inquiries I’ve received from eligible professionals who are being audited and don’t stand the slightest chance of passing an audit. There is the dermatologist who swears he was told there was no minimum number of patients he had to document in his ONC certified EHR to receive an $18,000 incentive in 2011. He received the infamous “audit engagement letter” last week. I asked him how many patients he saw during his 2011 meaningful use period and he answered, “Hundreds”. I asked him how many patients did he record in his EHR? “Six” was the reply. My advice? Do not pass Go, do not go through the audit, do not appeal. Pay the money back and go and sin no more. Those are the easy, black and white answers. However, I have also been running across some issues with those touchy nuances pertaining to the often foggy “public health” measures.
The Public Health measures have been slightly off the radar as they swish and sway down there in the Menu Measures for Eligible Professionals (EP) and Eligible Hospitals (EHs). Such Menu Measures as Immunizations, Syndromic Surveillance, and Reportable Lab Results continue to confuse and confound. Wouldn’t it be nice to pick one, claim an exclusion, and then be rid of it hopefully for all time? Just throw it over the fence and forget about it. These public health measures and the attestation strategies employed by both EPs and EHs are now starting to bear bitter fruit. I am working with a number of providers undergoing audits for their 2011 attestation in which the core area of concern is focused on the public health measures. Often the person that planned and carried out the 2011 attestations has moved on and there is no paper trail to document the logic behind the decisions as to which Menu Measures were chosen. If that wasn’t enough, a thorough audit will want documented proof supporting an exclusion claim. You say your state was unable in 2011 to receive immunizations electronically? Fine, provide that documentation to your auditor and move on. If you can’t, well you can see why this is a sticky area. For an EP this could be the tipping point between keeping or giving back that long gone $18,000 incentive. For an EH the stakes are much, much higher. We are talking millions here.
I’m thinking there were a lot of attestations that were just thrown together in 2011. There was so much money on the table. I can imagine the pressure that came from those at The Top to “Get those incentives!” Who wouldn’t want to make the boss happy with the news that the attestation was successful and the check was on its way? Tell the CEO, the CFO, and the Board, “It’s all good”. I haven’t talked to too many of those happy folks. The ones that contact me are the ones who are undergoing an audit or have failed one. The ones that are trying to piece together the what, how, and why that occurred two years ago. They ones sent in with mop and bucket to clean up the mess. Contact me here if you need help. Audit and appeal resources can be found here.
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