Presented by Lisa Gilmore, Draffin and Tucker

1. Medicare and Medicaid EHR Audits ofEligible Hospitals and Critical Access HospitalsHomeTown Health, LLCAttestation Support SessionOctober 22, 2013 Presented by Lisa Gilmore, Draffin and Tucker

2. Record Retention Period

3. Medicare Supporting Documentation • Attestation source documents • Copy of certification for EHR technology • Method chosen to report E/R admissions • CQM report • Numerators and denominators • Time period • Provider identification

4. CMS’ Suggested Documentation for Non-Percentage-Based Objectives Please note the suggested documentation does not preclude CMS from requesting additional information to validate attestation data.

5. CMS’ Suggested Documentation for Non-Percentage-Based Objectives

6. CMS’ Suggested Documentation for Non-Percentage-Based Objectives

7. Medicaid Supporting Documentation Myers and Stauffer may request the following items during their review: • Detailed encounter listing to support the eligibility calculation, which should include • Patient name • Medicaid member ID (if applicable) • Date of service, and • Payor source

8. Medicaid Supporting Documentation Myers and Stauffer may request the following items during their review: • Documentation to support discharges according to the applicable cost reports or other documentation utilized in calculating the growth rate and discharge-related amount • Documentation to support the Acute Medicaid Days, Acute Medicaid HMO days, and Total Acute days utilized in calculating the Medicaid share

9. Medicaid Supporting Documentation Myers and Stauffer may request the following items during their review: • Documentation to support Charity Care Charges and Total Hospital Charges utilized in calculating the Medicaid share • When appropriate, documentation to confirm the hospital had a legal or financial obligation to the Certified Electronic Health Record Technology at the time of A/I/U (Adopt, Implement, or Upgrade) attestation

10. How Can You Prepare for an Audit? • Understand meaningful use measures www.cms.gov Regulations and Guidance EHR Incentive Programs under Legislation Meaningful Use Downloads specification sheets

11. How Can You Prepare for an Audit? • Retain documentation for each meaningful use measure • Retain documentation for cost report data

12. How Can You Prepare for an Audit? • Continually monitor EHR certification and document certified version in use • Follow regulations when calculating Medicaid patient volume

13. Medicare Appeals

14. Georgia Medicaid Appeals

15. Mail request to: Georgia Department of Community Health DCH Medicaid EHR Incentive Program Request for Initial Administrative Review 2 Peachtree Street, N.W., 32nd Floor Atlanta, Georgia 30303 Must file within 30 calendar days from the date of decision • Step 1 – Request for Initial Administrative Review

16. Mail request to: Georgia Department of Community Health Office of the Commissioner Medicaid EHR Incentive Program Hearing Request 2 Peachtree Street, N.W., 40th Floor Atlanta, Georgia 30303 Must file within 30 calendar days from the date of the Initial Administrative Review Determination • Step 2 – Request for Hearing

17. File in the Superior Court of Fulton County or in the superior court of the provider’s county within 30 days after the Department of Community Health’s final decision Guidance located at O.C.G.A. § 50-13-19 • Step 3 – Petition for Judicial Review

18. Contact Information Lisa Gilmore Draffin & Tucker, LLP lgilmore@draffin-tucker.com 229-883-7878