dr bergers entrance. dr berger introduction hello … im dr. john berger. i would like to share with...

Dr Berger’s Entrance

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.

No worries.

We use a certified EHR product. Our vendor took

care of us.

Dr Berger Comments 3

What we found out was ….

… all was not so simple as we thought.

Dr Berger Comments 3

Let me share with you the

conversations we had along the way.

Dr Berger animation

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.

Introduction – Jackie Ford, Requirements Manager

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.

Introduction – Ron Holmes, Quality Manager

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

Introduction – Ron Holmes, Quality Manager

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.

Introduction – Ron Holmes, Quality Manager

I’m really sorry.

And, one more thing …

Introduction – Ron Holmes, Quality Manager

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”

Introduction – Ron Holmes, Quality Manager

So, even though we bought it in 2012, we were not certified in 2011, even though we thought

we were.

Introduction – Ron Holmes, Quality Manager

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.

So why didn’t

someone tell us???

Introduction – Ron Holmes, Quality Manager

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.

Introduction – Ron Holmes, Quality Manager

In the end, the auditors identified seven

deficiencies , any one of which would have disallowed our 2011

attestation.

Introduction – Ron Holmes, Quality Manager

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.

Introduction – Ron Holmes, Quality Manager

These regulations are complicated.

Someone should have told me.

Introduction – Ron Holmes, Quality Manager

Since then, we’ve taken some corrective actions so our other providers don’t

get hurt.

Take a look at these “Lessons Learned”

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.

Dr Berger’s Wrap up 3

So that’s the story of our CMS Audit, and what we learned.

Dr Berger’s Wrap up 3

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.

Dr Berger’s Wrap up 3

Be sure to check out

Meaningful Use

Monitor!

Jay Fisher414-640-2817

Jay.Fisher@C3Partners.biz

Chris Coleman414-640-2817

Chris.Coleman@C3Partners.biz

Contacts

http://MeaningfulUseMonitor.com