Dr Bergers Entrance

Dr Berger Introduction Hello … Im Dr. John Berger. I would like to share with you a recent Meaningful Use experience that gave me a little heartburn …

Dr Berger comments 1 We have a small clinic … only 10 physicians. About a month ago, we received notice that one of our physicians would be audited by CMS regarding their 2011 Meaningful Use Attestation.

Dr Berger comments 2 No worries. We use a certified EHR product. Our vendor took care of us.

Dr Berger Comments 3 What we found out was …. … all was not so simple as we thought.

Dr Berger Comments 3 Let me share with you the conversations we had along the way.

Dr Berger animation

Team Selection Slide Heres the call from the auditor

Hello, Dr. Berger. Well be auditing your 2011 Meaningful Use attestation, for which you received $18,000. CEO Comments 1

CEO Comments 2 Please provide documentation proving that you fulfilled all criteria, were using Certified EHR Technology, and were an eligible, non-hospital-based Medicare provider during the 2011 reporting period.

CEO Comments 2 So I called our Office manager to start the process.

Jackie, please arrange everything the auditor needs. Introduction – Jackie Ford, Requirements Manager

Jackies Comments 1 Ill start running the reports right away. We have upgraded our EHR since 2011, so we should be in good shape.

Jackies Comments 1 Thats when the trouble began

Jackies Comments 1 I got a call from our EHR vendor, after Jackie asked them to help out.

Jackies Comments 2 Hello, Dr. Berger. You realize that we cant really re-run 2011 reports, right?

Jackies Comments 2 For one thing, you are now on the 2013 version of our software, and those reports have changed.

Jackies Comments 2 … and even if we could do exactly the same reports, the patient data has changed, too. For example, theres no way we could identify whether smoking status was updated for any patient in 2011 … if youve seen that patient since then and updated their records. We only have current values.

Jackies Comments 2 That was a shock. But it got worse.

Jackies Comments 3 It seems our EHR creates reports against 16 percentage based measures. But …

Jackies Comments 4 There are another nine items the auditors want to see and there are no reports at all from the EHR on those.

Jackies Comments 4 They want proof that we followed a clinical decision support rule, integrated with the hospital and tested the EHRs ability to do electronic syndromic surveillance. We dont have reports for those.

Jackies Comments 4 Next, I got a call from our IT consultant.

Introduction – Ron Holmes, Quality Manager Uhhh … Dr. Berger? The auditors want a copy of a HIPAA privacy and security review. But the EHR vendor told us that if we were using their Certified Product, we were covered for HIPAA

Introduction – Ron Holmes, Quality Manager Now the auditor says that is not enough. We need a copy of the Privacy and Security Review from … and we didnt do anything like that.

Introduction – Ron Holmes, Quality Manager Im really sorry. And, one more thing …

Introduction – Ron Holmes, Quality Manager Remember how we were trying to save some money in 2011? And we decided not to by the extra Lab module? Well … we found out that the Lab module had to be part of the EHR in order for us to really be Certified

Introduction – Ron Holmes, Quality Manager So, even though we bought it in 2012, we were not certified in 2011, even though we thought we were.

Introduction – Ron Holmes, Quality Manager We thought we were good. We bought the Certified product after all … just not all of it. And the auditor says thats not good enough. Im really sorry. It is a great EHR, though. So why didnt someone tell us???

Introduction – Ron Holmes, Quality Manager Thing is … hes right. It is a great EHR. But I counted on them for Meaningful Use, and that just didnt work out.

Introduction – Ron Holmes, Quality Manager In the end, the auditors identified seven deficiencies, any one of which would have disallowed our 2011 attestation.

Introduction – Ron Holmes, Quality Manager So I had to write a check to CMS to repay the $18k stimulus money I received in Talk about disappointment. I was hopping mad.

Introduction – Ron Holmes, Quality Manager These regulations are complicated. Someone should have told me.

Introduction – Ron Holmes, Quality Manager Since then, weve taken some corrective actions so our other providers dont get hurt. Take a look at these Lessons Learned

Lesson 1: You cant change the past! Meaningful Use Audits are against a prior year, and you cant create documentation you didnt save in the first place.

Lesson 2: Your EHR Vendor cannot do it all You have to document a number of actions, decisions and tests that dont come from your EHRs reporting tools.

Lesson 3: The regulations are not simple Find some good expertise, and ask questions frequently. Get some formal training.

Lesson 4: Attestation and payment are not the End Game Audits can occur for several years after youve received your money, and you need to retain documentation of each single year. Just like income taxes.

Dr Bergers Wrap up 3 So thats the story of our CMS Audit, and what we learned.

Dr Bergers Wrap up 3 Since then, our EHR vendor has made some really positive changes. They now provide us something called the Meaningful Use Monitor And it gives us the formal expertise and tools to withstand an audit. I highly recommend you take a look at it, so you dont have the bad experience we did.

Dr Bergers Wrap up 3 Be sure to check out Meaningful Use Monitor!

Jay Fisher Chris Coleman Contacts