Meaningful Use Audits for Medicare and Medicaid. Shay Surowiak, RN, BSN, CHTS-CP HIT Practice Advisor

Meaningful Use Audits for Medicare and Medicaid Shay Surowiak, RN, BSN, CHTS-CP HIT Practice Advisor

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Mission of OFMQ OFMQ is a not-for-profit, consulting company dedicated to advancing healthcare quality. Since 1972, we ve been a trusted resource through collaborative partnerships and hands-on support to healthcare communities.

HIT Service Lines Security & Privacy Risk Analysis Security & Privacy Validation Meaningful Use Gap Analysis Meaningful Use Gap Audit Meaningful Use Attestation HIPAA Security Preparedness HIPAA Privacy Preparedness Staff IT Security Training

OFMQ Expanded Service Lines Analytics Case Review Education IT Consulting Health Information Technology National Quality Measures Quality Improvement

Shay Surowiak, BSN, CHTS-CP She consults with physician offices/practices related to all aspects of the use of Electronic Health Record (EHR) systems implementation life-cycle. She supports work for HIT-related contracts including the Centers for Medicare and Medicaid Services (CMS), non- CMS contracts, and the use of health information technology in physician offices to improve patient care outcomes. Previously, Shay spent the majority of her nursing career working on various quality improvement projects utilizing (EHR) technology to promote quality patient care and decrease healthcare expenditures.

During this presentation we will review: New CMS rule allowing flexibility in certified EHR technology for 2014 The Oklahoma Healthcare Authority are required to audit Meaningful Use processes, and the audits Will be taking place in the very near future - your preparation should be as well. Don't get caught by surprise! What steps should be taken if you get a Audit Engagement Letter/Email from Centers for Medicare and Medicaid Services (CMS) to audit your Meaningful Use attestation

MUST HAVE SUFFICIENT DOCUMENTATION FROM VENDOR TO SUPPORT YOUR REASONING FOR DELAY *Only providers that could not fully implement 2014 Edition CEHRT for the EHR reporting period in 2014 due to delays in 2014 Edition CEHRT availability. If you were scheduled to demonstrate: Stage 1 in 2014 Stage 2 in 2014 You would be able to attest for Meaningful Use: Using 2011 Edition CEHRT to do: 2013 Stage 1 objectives and measures* 2013 Stage 1 objectives and measures* Using 2011 & 2014 Edition CEHRT to do: 2013 Stage 1 objectives and measures* -OR- 2014 Stage 1 objectives and measures* 2013 Stage 1 objectives and measures* -OR- 2014 Stage 1 objectives and measures* -OR- Stage 2 objectives and measures* Using 2014 Edition CEHRT to do: 2014 Stage 1 objectives and measures 2014 Stage 1 objectives and measures* -OR- Stage 2 objectives and measures 9

For more Information on the Auditors: Please visit: Figliozzi and Company s website at http://www.figliozzi.com/ The Oklahoma Healthcare Authority www.okhca.org

Official Audit Letter

Email Notice from Auditor

2013 EHR Incentive Program Changes As long as the provider has a valid SoonerCare contract at the time of attestation, the provider is eligible to participate in the EHR Incentive Program.

What is an Encounter? Encounter is now defined as any service rendered to a patient on any one day regardless of payment liability. What this means is; as long as the provider can prove an encounter occurred regardless if the encounter was paid, denied, billed, etc., it can be used to calculate patient volume.

Please take note!! OHCA will require the provider to distinctly identify the total number of billed Medicaid encounters and the total number of non-billed Medicaid encounters for the purposes of prepayment verification.

Patient Volume Patient volume can now be calculated by using encounters from a 90 day period in either the previous calendar year or the most recent 12 months prior to the date of attestation.

What will they request? The audit is broken down into three sections: Part 1- General Information Part 2- Core Set Objectives/Measures Part 3- Menu Set Objectives/Measures

Part 1- General Information Licensing agreement with vendor or invoice List of offices or outpatient facilities the EPs sees patients Documentation that 80% of your patient records are maintained in a CEHRT system in all facilities

Part 2- Core Set Objectives/Measures Core Measure Meaningful Use Report used for Attestation - Should include a EHR logo on report or provide screenshots

Part 2- Core Objectives/Measures Found on Meaningful Use Report (Stage 1) Computerized Physician Order Entry (CPOE) Up-to-date Problem List Generate & transmit prescriptions electronically (erx)-ep s Only Active Medication List Active Allergy List Record Patient Demographics Record Vital Signs Record Smoking Status Provide timely online access to health information Clinical Visit Summaries for Patients EP s Only 20

Part 2 - Core Objectives/Measures Found on Meaningful Use Report (Stage 2) CPOE (Computerized Physician Order Entry) Generate & transmit prescriptions electronically (erx) EP s Only Record demographics Record vital signs Record smoking status Structured lab results emar - EH s Only Reminders for preventative/follow-up care Provide timely online access to health information Provide clinical visit summaries EP s Only Provide patient education resources Secure messaging with patients EP s Only Medication reconciliation Provide summary of care document 21

Part 2- Example: MU Report Used for Attestation

Part 2 Core Objectives/Measures (Continued) For all Yes/No Core Measures -Supply Screen shots

Part 2- Core Objectives Yes/No Measures (Stage 1) Drug-Drug & Drug-Allergy Checks Implement at least 1 Clinical Decision Support and Track Compliance Conduct Security Risk Analysis 24

Part 2- Core Objectives Yes/No Measures (Stage 2) Implement 5 Clinical Decision Support (CDS) rules Generate lists of patients by condition Submit electronic data to immunization registry Conduct security risk analysis Submit reportable lab results to public health agencies EH s Only Submit syndromic surveillance data to public health agencies EH s Only 25

Part 2- Example: Core Measure Yes/No Screenshot

Part 3- Menu Set Objectives/Measures Menu Measure Meaningful Use Report used for Attestation -Should include a EHR logo on report or provide screenshots

Part 3- Menu Objectives/Measures Found on Meaningful Use Report (Stage 1) Clinical Lab Results as Structured Data Provide Patient Specific Education Resources Medication Reconciliation between Care Settings Summary of Care Records for Patients Patient Reminders EP s Only Advance Directives EH s Only 28

Part 3- Menu Objectives/Measures Found on Meaningful Use Report (Stage 2) Imaging results accessible through EHR Record family health history Electronic progress notes erx EH s Only Advanced directives EH s Only Provide structured lab results to EP s EH s Only 29

Part 3 Menu Set Objectives/Measures (Continued) For all Yes/No Menu Measures -Supply Screen shots

Part 3- Menu Objectives Yes/No Measures (Stage 1) Drug Formulary Checks Lists of Patients by Condition Electronic Immunization Data Submission Electronic Syndromic Data Submission Electronic Reportable Lab Results Data Submission- EH s Only

Part 3- Menu Objectives Yes/No Measures (Stage 2) Submit electronic syndromic surveillance data to public health agencies EP s Only Identify and report cancer cases to cancer registry EP s Only Identify and report specific cases to a specialized registry (other than cancer) EP s Only

Timelines 14 Business days to submit the requested information after initial contact from Figliozzi

How to Supply Requested Information 1. Electronically uploading the requested information to their secure web portal (they will provide step by step instructions) 2. Mail in the requested information

If you do not PASS the first round of Audits... If the auditors feel like you did not supply sufficient documentation the first time then they may ask for additional information In this scenario you will have 7 Business days to comply

Additional Requested Information Part 1- General Information: You provided the auditors with a licensing agreement with your EHR vendor, BUT They need proof from your vendor that you were using the certified version of your EHR when you attested.

Additional Requested Information Part 2 & 3- Core and Menu Yes/No objectives: You supplied all screen shots for Yes/No measures used for attestation, BUT.. They need proof that this functionality was turned on the entire reporting period. Provide proof with an audit trail.

Part 2 & 3- Example: Yes/No Measure Audit Trail

Additional Requested Information Part 2 & 3- Core and Menu Yes/No Measures (cont d): Security and Privacy Risk Assessment- You supplied a screen shot of your Findings page, BUT They have requested the entire analysis to: verify procedures performed and risks implementation plan to mitigate risks. Identification of person completing assessment as well as the date completed

What is recommended to prove that my office has complied with Core Measure Privacy and Security Assessment? It is the responsibility of the provider to determine if they have met the requirements of 45 CFR 164.308 (a)(1) and correctly identified security deficiencies as part of its risk management process. OHCA requests that you provide the identification of the person completing the assessment and the date complete. The assessment has to be completed and identified deficiencies corrected (or a plan of correction in progress) prior to the end of the EHR reporting period. The assessment could have occurred prior to the beginning of the reporting period; however, a new review will have to be conducted for each subsequent reporting period 40

Part 2 & 3- Example: Yes/No Measure Security & Privacy

When the audit is concluded.. You will receive an Audit Determination letter from Figliozzi and Company. If you PASS the letter will state that you have successfully achieved Meaningful Use o If you FAIL your payment will be recouped

In Conclusion Be aware of timelines if you receive a letter or email The auditor has the right to request additional information. Will only give you 3 chances Retain ALL relevant supporting documentation (in either paper or electronic format) Documentation should be saved for 6 years Prepare NOW!

Questions & Answers If you re interested in improving your practice and office efficiency through EHR software use or our service lines, contact us! Email: ofmqhit@ofmq.com Call: (877) 963-6744 Visit: www.ofmqhit.com

Questions?

Upcoming Events Our Next WebEx Seminar Wed, Oct 15 12:15pm (Central Time) EHR Incentive Program Updates & New Stage 2 Final Rule for 2014 Register at www.ofmq.com/event-month

Thank you! ofmqhit@ofmq.com 877-963-6744