1. 2015 User Conference Surviving an MU Audit April 24, 2015 1:15 pm Guest Speaker: Grace Bell NYC REACH, New York City Regional Extension Center Co-presenter: Cindy Malek Training Specialist EHR Session

2. 2 Primary Care Information Project How to Prepare for Medicaid Meaningful Use Audits K. Grace Bell Health Systems Quality Manager NYC REACH | NYC Regional Extension Center Primary Care Information Project | NYC Department of Health & Mental Hygiene Office Practicum Users Conference 2015 April 24, 2015

3. 3 Primary Care Information Project Agenda Introduction and Background Basic Meaningful Use Audit Information Audit Preparation: How to prepare now! During an Audit: How to handle an ongoing audit? Tips & Suggestions Open Discussion and Questions

4. 4 Primary Care Information Project Introduction: Meaningful Use Policy Pre 2009 A system under equipped to meet the needs 2009 $20 billion to fund EHR Incentive Program & 62 Regional Extension Centers 2014 + Widespread adoption and meaningful use of EHRs

5. 5 Primary Care Information Project Introduction: Map of Regional Extension Centers Source: http://www.healthit.gov/providers-professionals/listing-regional-extension-centers#listing

6. 6 Primary Care Information Project Introduction: Primary Care Information Project/NYC REACH History PCIP, a bureau of NYC DOHMH, was founded by Mayor Bloomberg in 2005 Awarded Regional Extension Center Grant in 2010 Mission Improve the quality of care in medically underserved areas through health information technology (HIT) Assist providers with the adoption, implementation, and utilization of Electronic Health Records (EHR) Success Over 16,000 providers receiving EHR and Meaningful Use assistance

7. 7 Primary Care Information Project Introduction: Meaningful Use Stages Source: www.ehealthdc.orgwww.ehealthdc.org

8. 8 Primary Care Information Project Don’t qualify for either program? You may still be asked to submit Meaningful Use information if you participate in other programs, such as ACOs, PCMH, or DSRIP. Introduction: Meaningful Use Program Details Medicare ProgramMedicaid Program Payment amount is determined by your Medicare claims Qualification determined by 30% Medicaid Patient Volume demonstration Skipping years = lose out on a year of payment Can skip years and get payment 1 year later Payments until 2016earn 6 years of payments until 2021 2014 was the last year to begin the incentive program 2016 is the last year to begin the program up to $24,000 (if you started MU in 2014) up to $63,750

9. 9 Primary Care Information Project Introduction: MEDICAID Incentive Program Breakdown 20112012201320142015 2011AIU (up to $21,250) 201290 days of MU Stage 1 (up to $8,500) AIU (up to $21,250) 2013Full year of MU Stage 1 (up to $8,500) 90 days of MU Stage 1 (up to $8,500) AIU (up to $21,250) 201490 days of MU Stage 2 (up to $8,500) 90 days of MU Stage 1 (up to $8,500) 90 days of MU Stage 1 (up to $8,500) AIU/90 days of MU Stage 1 (up to $21,250) 2015Full year of MU Stage 2 (up to $8,500) Full year of MU Stage 2 (up to $8,500) Full year of MU Stage1 (up to $8,500) 90 days or Full year of MU Stage 1 (up to $8,500) AIU or 90 days of MU Stage 1 (up to $21,250) Year you began the MU Program Current Year

10. 10 Primary Care Information Project Agenda Introduction and Background Basic Meaningful Use Audit Information Audit Preparation: How to prepare now! During an Audit: How to handle an ongoing audit? Tips & Suggestions Open Discussion and Questions

11. 11 Primary Care Information Project Basic Audit Information: General Guidelines Audit processes vary slightly between programs and states, but overall there are many similarities CMS (Medicaid and Medicare) will follow standard guidelines used for CMS programs with audit provisions, including auditing providers based on a random selection process, as well as selection based on key identifiers such as prior audit failure or known incidence of fraud. Providers will not be targeted by provider type, location, stage of Meaningful Use, or participation year.

12. 12 Primary Care Information Project Basic Audit Information: When and by Whom? CMS contracts with Figliozzi and Company for audits related to the Medicare Meaningful Use program Medicaid contracts with an internal office (Office of the Medicaid Inspector General) for Medicaid Meaningful Use program Providers should keep their information for 6 years in case of future audits. Notification for audits can also occur prior to payment. Be prepared as soon as you hit submit! Notification for the audit will be given by email. It will also be given secondarily by mail. Make sure your CMS Registration is up to date with an email address that you check regularly and the correct mailing address. Response time varies by auditing body, but on average you will only have 4 weeks to complete a response. Don’t miss the window by missing the email from your auditor!

13. 13 Primary Care Information Project Basic Audit Information: Selection Selection for audit is not a clear formula, but there are some key red flags to think about: EHR Vendors review lists of attesting providers to ensure that providers claiming their EHR Certification ID align with providers using their systems Medicaid eligibility discrepancies between attestation and state data Numerator and denominators for measures that do not make sense. For example, numerators and denominators that are the same for every measure. CMS plans to audit 5 – 10% of all providers that have attested to Meaningful Use for each payment year. Medicaid audit percentages vary by state, but often mirror the CMS percentages.

14. 14 Primary Care Information Project Agenda Introduction and Background Basic Meaningful Use Audit Information Audit Preparation: How to prepare now! During an Audit: How to handle an ongoing audit? Tips & Suggestions Open Discussion and Questions

15. 15 Primary Care Information Project Audit Preparation: Setting Up the Folder Create a Meaningful Use folder. In that folder make sure to save all relevant and necessary Meaningful Use items and documents. It is also a good idea to have a printed copy in a safe location. Have a Back-up! You should have an electronic copy of your MU Folder saved in a second location or have a printed back-up copy…just in case! Save your Meaningful Use Dashboard in case of future audits. Save this both in printed form and scan it back and save it in the Meaningful Use folder on your computer. Save your Medicaid Eligibility in your Meaningful Use folder. This numerator and denominator should be able to be recreated by the provider either from the EHR, billing system, or by hand in case of audit. Please be mindful that this report has patient health information and should be saved accordingly. Meaningful Use 2015

16. 16 Primary Care Information Project Audit Preparation: Yes/No Measures You will need screenshot proof for ALL your Yes/No measures on the report: Stage 1 & 2 Core Requirement: Drug-Drug, Drug-Allergy Interaction Checks – Prove that this interaction are checked in the Medication Finder Stage 1 & 2 Core Requirement: Implement Clinical Decision Support Rule(s) relevant to specialty of clinical priority – Screenshot demonstration through the custom care plan feature Stage 1 Menu Measure & Stage 2 Core Measure: Implement Drug Formulary Check – Ensure drug formulary is checked in the Medication finder Stage 1 Menu Measure & Stage 2 Core Measure: Run Patient List – Save a copy of your Demographic Analysis list from the Reports tab. Please note that this report will have patient information and should be saved accordingly. HINT! To screenshot all you need to do is look at your keyboard press and hold CTRL (bottom left) and then press PRINTSCRN (top right)

17. 17 Primary Care Information Project Audit Preparation: Public Health Reporting Stage 1 Menu Measure and the Stage 2 Core Measure: Immunization Registry If you completed the measure…you can save a screenshot of an uploaded vaccine from OP, or a screenshot of your agency immunization registry as proof. HINT! Save an example from within your reporting period! If you are exempt from this measure…remember to write down why, in case you are asked in the future. Stage 1 and Stage 2 Menu Measure: Syndromic Surveillance If you completed the measure…the email confirmation you received from your public health agency is your proof If you are exempt from this measure…remember to write down why, in case you are asked in the future.

18. 18 Primary Care Information Project Audit Preparation: Security Risk Assessment For the Security Risk Assessment the Excel document you worked on is proof enough and you do not need additional screenshot proof. Please save the Risk Assessment and all associated documents and templates in your Meaningful Use folder. The security risk analysis may be completed outside or within the EHR reporting period timeframe, but must take place no earlier than the start of the reporting year and end of the reporting year. This means you need to update this document annually, but keep old versions saved! In addition to the Security Risk Assessment, make sure to save all office policies associated with the Security Risk Assessment. All policies should be saved in a location accessible during an audit, but do not need to be saved in the Meaningful Use folder.

19. 19 Primary Care Information Project Audit Preparation: 2014 Flex Rule Documentation CMS will provide guidance to auditors relating to the 2014 CEHRT Flexibility final rule and the attestation process. Auditors will be instructed to work closely with providers on the supporting documentation needed that is applicable to the provider’s individual case. Obtain and save all EHR vendor documentation related to qualifying for the CEHRT option. Here is the letter that Office Practicum sent! “As such, you will qualify for the "availability delay" exemption, because you cannot achieve a full 90 day reporting period in 2014.”

20. 20 Primary Care Information Project Agenda Introduction and Background Basic Meaningful Use Audit Information Audit Preparation: How to prepare now! During an Audit: How to handle an ongoing audit? Tips & Suggestions Open Discussion and Questions

21. 21 Primary Care Information Project During an Audit: Notifications You will receive a direct notification from your auditor, either from OMIG or Figliozzi. This person will be your contact person throughout your audit. Each auditor is different, so work with them to determine what information you need to share for your audit. If they don’t ask for it, don’t share it. Read your audit communications carefully to determine what information they are looking to review. If your auditor stops responding be patient, but also don’t wait too long! Reach out to Figliozzi or OMIG to ensure that you can continue to move forward with this process.

22. 22 Primary Care Information Project During an Audit: Adopt/Implement/Upgrade Audits For the first year of Medicaid, Adopt/Implement/Upgrade (AIU), there are two main sections to the audit: Medicaid Eligibility – Reaching the 30% Medicaid threshold, or the 20% for the 2/3 payment How? The provider will need to document each individual patient encounter seen during this 90 days, including patient name, date of service, Medicaid status at the time of the report, etc. Contract with a Certified EHR – Demonstration that the provider had at least a contract with a Certified EHR How? The provider will need to submit a contract from the EHR vendor or a past payment statement demonstrating that the EHR was in possession during the time that the provider attested for the AIU payment.

23. 23 Primary Care Information Project During an Audit: Meaningful Use Audits For the second year and beyond of Meaningful Use, there are two main sections to the audit: Medicaid Eligibility – Reaching the 30% Medicaid threshold, or the 20% for the 2/3 payment How? The provider will need to document each individual patient encounter seen during this 90 days, including patient name, date of service, Medicaid status at the time of the report, etc. Meaningful Use Measures – Did the provider meet the Meaningful Use measures that he/she attested to for this attestation? How? The provider will need to submit Meaningful Use reports, screenshots, additional documents (such as the Security Risk Assessment). Areas of Concern: Providers should be ready to show proof that they have met the Yes/No measures (proof requirements will vary by audit) and providers who work at multiple locations need to merge data as necessary.

24. 24 Primary Care Information Project During an Audit: Frequently Asked Questions What if my Medicaid Eligibility numbers do not match what I submitted? Generally, this is fine as long as you still meet the 30% or 20% Medicaid thresholds. Most importantly, share the information you have to the best of your ability even if it does not match exactly! What if I do not have my old Meaningful Use dashboard? First, work with your vendor! If you are unable to find the old Meaningful Use dashboard speak candidly with your auditor for suggestions and tips! What if I did not take screenshots in previous years? Work with your auditor. In many cases, the yes/no measures are automatic in the system so you might be able to get a letter from your vendor that states that you met the measures automatically. What if I did not do or did not save my Security Risk Assessment? Do it now! This measure is one of the most challenging measures. Even if you have not completed an SRA to date, I recommend that you complete one now!

25. 25 Primary Care Information Project Agenda Introduction and Background Basic Meaningful Use Audit Information Audit Preparation: How to prepare now! During an Audit: How to handle an ongoing audit? Tips & Suggestions Open Discussion and Questions

26. 26 Primary Care Information Project Tips & Suggestions: Audit Failure Not everyone passes… If you fail an audit you will need to work with your auditor to repay the money earned. Continue with Meaningful Use even if you fail one audit. While you have to repay the money, you can still move forward to earn more incentives. Audit failure does not mean you are out of Meaningful Use completely. If you fail an audit and you would like to appeal, most offices give you 60 days to submit an appeal. Contact your audit agency to learn about your state specific documentation necessary to appeal your audit decision. Documentation from earlier audits is saved, so make sure to follow all audit preparation steps for all future payments.

27. 27 Primary Care Information Project Tips & Suggestions: Final Thoughts Prepare in case of an audit! Make an MU Folder, take the necessary screenshots, and save your MU Dashboards every year! Work with Office Practicum to help find any missing documentation for contracts or past MU reports if you are already in an audit process. Check your email! You don’t want to miss crucial time because you missed the email. Talk to your auditor if you are unsure about what they are asking or if you need an extension as you are trying to gather information. Make sure you ask for the extension BEFORE you miss the deadline. Be Honest! Your information might not be perfect and it might not match exactly. Be honest with your auditor if there is something that looks a little different.

28. 28 Primary Care Information Project Agenda Introduction and Background Basic Meaningful Use Audit Information Audit Preparation: How to prepare now! During an Audit: How to handle an ongoing audit? Tips & Suggestions Open Discussion and Questions

29. 29 Primary Care Information Project Questions? Contact Information: Grace Bell, Health Systems Quality Manager NYC REACH, New York City Regional Extension Center 347-396-4910 gbell1@health.nyc.gov Questions