The journey from denial to acceptance who, what, me?

Transcription

1 The Compliance Officer s Role in Meaningful Use Nancy Vogt, RHIT, CHC, CHP Director/Deputy Chief Compliance Officer Aurora Health Care Milwaukee, Wisconsin The journey from denial to acceptance who, what, me? EHR Incentive Program is new and complex, with many moving parts Can be significant dollars Incentives now, penalties in 2015 Security risk assessment/mitigation 2012 OIG Work Plan 1

2 Leadership certification I certify that the foregoing information is true, accurate, and complete. I understand that the Medicare EHR Incentive Program payment requested will be paid from Federal funds, and that the use of any false claims, statements, or documents, or the concealment of material fact used to obtain Medicare EHR Incentive Program payment, may be prosecuted under applicable Federal or State criminal laws and may be subject to civil penalties. Where to begin? CMS Specification Sheets 3. Federal Register commentary 4. CMS FAQ s 5. ONC FAQ s (healthit.hhs.gov) 6. Federal advisory committee meeting minutes 7. EHR Information Center ( ) 8. EHR Incentive Programs Listserv 2

3 Meaningful use in a nutshell ARRA/HITECH incentive program Use certified EHR technology Be a meaningful EHR user Attest for incentive payments The use of certified EHR technology: In a meaningful manner (3 stages) For electronic exchange of health information to improve quality of health care To report/submit clinical quality and other measures Why? 1. Improve quality, safety, efficiency, and reduce health disparities 2. Engage patients and families 3. Improve care coordination 4. Improve population and public health 5. Ensure adequate privacy and security protections for personal health information 3

4 Medicare vs Medicaid Programs Medicare EHR Incentive Program: Eligible participants must successfully demonstrate MU of certified EHR technology for 90-day period in first year, then a full year thereafter Medicaid EHR Incentive Program Eligible participants may qualify for incentive payments if they adopt, implement, upgrade or demonstrate MU in their first year Adopted = acquired and installed Implemented = have begun using certified EHR technology Upgraded = expanded existing technology to meet certification requirements Must successfully demonstrate MU for subsequent years Eligibility (and this is the easy part) 4

5 And now for the nutty part Hospital Requirements 19 measures (14 core, 5 from menu of 10-1 of which must be public health) 15 core clinical quality measures Eligible Professional Requirements 20 measures (15 core, 5 from menu of 10) 6 clinical quality measures (3 core, 3 alternate core, 3 of 38 additional measures) Of course we own a certified EHR (or two) EHR vendor certification methods: modular or complete (or both?) Using certified functionality (no good innovation goes unpunished) Possessing functionality for deferred measures (ONC FAQ ) Clinical quality measure reports (ONC FAQ ) 5

6 Certification The measures are clear and simple, aren t they? Hospital Testing exchange Clinical quality measures E-copies Protect electronic health information Smoking status Demographics Clinical lab test results 6

7 The measures are clear and simple, aren t they? EP Clinical Summaries Clinical quality measures CPOE eprescriptions Vital signs Checking on the clear and simple CPOE: only licensed health care professionals Content of clinical summaries ( after-visit summaries ) Offering electronic discharge instructions Drug formulary and interaction checks on Patient list generated Security risks addressed 7

8 Accurate clinical quality measures? Abstracting Accurate and complete FAQ 10589: CMS considers information to be accurate and complete for CQM s insofar as it is identical to the output that was generated from certified EHR technology AHA: results can vary from those derived through existing manual abstraction The road to attestation Standing meetings External counsel Routine tracking EHR policy team Reference tools Advocate for clear regulations 8

9 Attesting with confidence Register early Determine the role of Compliance Attesting individual will have access to payment information Constitutes submitting a claim Mock audit Documentation for accurate attestation Documentation and report retention Sample attestation document # Measure Information Measure Values 1 Objective: Use computerized provider order entry (CPOE) for medication orders directly entered by any licensed health care professional who can enter orders into the medical record per state, local, and professional guidelines. Measure: More than 30 percent of all unique patients with at least one medication in their medication list admitted to the eligible hospital s or CAH s inpatient or emergency department (POS 21 or 23) have at least one medication order entered using CPOE Goal: >30% Score: 95.1% Numerator: Number of patients in the denominator that have at least one medication order entered using CPOE Denominator: Number of unique patients with at least one medication in their medication list seen by the eligible hospital or CAH during the EHR reporting period 9,852 10,365 9

10 Reports a snapshot in time Audit-readiness Per CMS website: Save the supporting electronic or paper documentation that support your attestation. Save the documentation to support your Clinical Quality Measures (CQMs). Hospitals should maintain documentation to support their payment calculations. 10

11 Non-numerical measure examples Screen shots to provide evidence of: Testing exchange Drug formulary and interaction checks Smoking nomenclature One decision support rule (hospital) Sources of CQM data Examples of structured clinical lab Public health exchange (we included interface transactions) E-copy process flow Security risk assessment and mitigation Sample patient list (hospital) Other Documentation EHR vendor contract Report specifications Certification documents, if any Attestation confirmation 11

12 What if (oh no!) a mistake was made? Could be vendor or provider Repayments may be required if reports over-reported compliance with a measure Lessons learned Significant time requirement; varied with implementation The value of diversity in the compliance team knowledge of I.T. The value of clear ownership Documentation (in case you really do get hit by a bus) 12

13 On the horizon Questions 13