• Meaningful use reports for various at- tested measures with the EHR vendor logo on them to confirm they came from the indicated CEHRT system;
• Audit trails to prove certain function- ality, such as drug interaction, clinical rules, and drug formulary checking, was enabled during the attestation period;
• Additional information on core mea- sure 14, electronic exchange of clini- cal information, that confirms the date of exchange, the name of the sending and receiving providers, and success or failure of the exchange; and
• Additional information on core mea- sure 15, security risk analysis, that helps to determine the analysis com- pletion date, notation of risks or defi- ciencies during the analysis, and the presence of an implementation plan to deal with identified deficiencies.
The second email from Figliozzi con-
cluded by warning “if the aforemen- tioned meaningful use criteria are not met, the incentive payment will be re- couped.” Dr. Sachdev says some of the docu- mentation requested was impossible to provide. His EHR vendor, eMDs, gives him and other users an audit guide he says Figliozzi reviewed and approved. “Despite this, they went on to request additional information that they knew eMDs software could not provide, spe- cifically, the audit trails and meaning- ful use reports with the eMDs logo on them,” he said. “I supplemented this information instead with step-by-step screenshots showing how the reports are generated through the EHR. I am hoping that this will satisfy their requirement to demonstrate that the reports did indeed originate from my EHR. It remains to be seen whether Figliozzi will accept this.” Dr. Sachdev believes Figliozzi select-
ed him at random. He has since attested to year two of Stage 1 meaningful use in the Medicare EHR incentive program but hasn’t yet received his $12,000 payment. “After going through the stress and frustration involved with gathering the requested additional information, which was barely done within the seven-day
time frame, I find myself once again in limbo. During this lengthy waiting pe- riod, as a doctor, you’re wondering if you’ll be asked to write them a check for $18,000 at some point,” he said.
Documentation critical Given his experience, Dr. Sachdev urges physicians who have attested to mean- ingful use or who plan to attest to docu- ment the process carefully. “As you prepare to attest to each objec-
tive, consider not only the numerators and denominators; think of how you will prove that you met each objective during the reporting period. You must anticipate and prepare for an audit. Not only could you be required to return the incentive money you earned, but failing an audit could expose you to future pen- alties for not successfully attesting,” he said.
Health professionals in the Medi- care incentive program can earn up to
Where to get help
Here’s where you can get help and information if you’re select- ed for a meaningful use audit.
CMS EHR incentive programs supporting documentation for audits
http://go.cms.gov/WjRCM6
TMA Health Information Technology Department (800) 880-5720 Email:
HIT@texmed.org
TMA EHR Incentive Program Resource Center
www.texmed.org/EHRIncentive
Regional extension center (REC) service regions map and contacts
www.texmed.org/rec Texas’ RECs educate clients on the potential for audits and the need to maintain documentation.
Texas Medicaid & Healthcare Partnership (800) 925-9126, option 4
www.tmhp.com
Figliozzi & Company (516) 745-6400
www.figliozzi.com
June 2013 TEXAS MEDICINE 33
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