Dr Berger’s Entrance. Dr Berger Introduction. Hello … I’m 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.
Hello … I’m Dr. John Berger.
I would like to share with you a recent Meaningful Use experience that gave me a little heartburn …
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.
We use a certified EHR product. Our vendor took care of us.
What we found out was ….
… all was not so simple as we thought.
Let me share with you the conversations we had along the way.
Here’s the call from the auditor
Hello, Dr. Berger. We’ll be auditing your 2011 Meaningful Use attestation, for which you received $18,000.
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.
So I called our Office manager to start the process.
Jackie, please arrange everything the auditor needs.
I’ll start running the reports right away.
We have upgraded our EHR since 2011, so we should be in good shape.
That’s when the trouble began
I got a call from our EHR vendor, after Jackie asked them to help out.
Hello, Dr. Berger.
You realize that we can’t really re-run 2011 reports, right?
For one thing, you are now on the 2013 version of our software, and those reports have changed.
… and even if we could do exactly the same reports, the patient data has changed, too.
For example, there’s no way we could identify whether “smoking status” was updated for any patient in 2011 … if you’ve seen that patient since then and updated their records. We only have current values.
That was a shock. But it got worse.
It seems our EHR creates reports against 16 percentage based measures. But …
There are another nine items the auditors want to see and there are no reports at all from the EHR on those.
They want proof that we followed a clinical decision support rule, integrated with the hospital and tested the EHR’s ability to do electronic syndromic surveillance. We don’t have reports for those.
Next, I got a call from our IT consultant.
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
Now the auditor says that is not enough. We need a copy of the “Privacy and Security Review” from 2011.
… and we didn’t do anything like that.
I’m really sorry.
And, one more thing …
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”
So, even though we bought it in 2012, we were not certified in 2011, even though we thought we were.
So why didn’t someone tell us???
We thought we were good. We bought the Certified product after all … just not all of it.
And the auditor says that’s not good enough.
I’m really sorry. It is a great EHR, though.
Thing is … he’s right.
It is a great EHR. But I counted on them for Meaningful Use, and that just didn’t work out.
In the end, the auditors identified seven deficiencies , any one of which would have disallowed our 2011 attestation.
So I had to write a check to CMS to repay the $18k stimulus money I received in 2011.
Talk about disappointment. I was hopping mad.
These regulations are complicated.
Someone should have told me.
Since then, we’ve taken some corrective actions so our other providers don’t get hurt.
Take a look at these
Lesson 1: You can’t change the past!
Meaningful Use Audits are against a prior year, and you can’t create documentation you didn’t 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 don’t come from your EHR’s 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 you’ve received your money, and you need to retain documentation of each single year. Just like income taxes.
So that’s the story of our CMS Audit, and what we learned.
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 don’t have the bad experience we did.
Be sure to check out Meaningful Use Monitor!