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CMS Plans To Audit 5 Percent of Meaningful Use Participants

Are you ready to be reviewed? Well, get prepared. As part of its ongoing program of supervision, CMS plans to audit 5 percent of participants in the Meaningful Use program for compliance, according to Modern Healthcare.

Since January, CMS has been auditing program participants that have already received their money, as well as those who have applied to receive incentive payments. Going forward, the two groups will receive about the same level of attention, with a total of 5 percent of program participants ending up getting closer scrutiny from the feds, MH reports.

To date, there haven’t been many adverse findings by CMS, though the agency has discovered a few questionable situations, Robert Anthony, deputy director of the HIT Initiatives Group at CMS, told the magazine. But a few providers are already beginning the appeal process, and several providers may face fraud enforcement investigations, he said.

The bulk of the Meaningful Use reviews will be what the agency dubs “desk audits,” done by the CMS audit contractor Figliozzi and Co., in which information is exchanged electronically. However, a few on-site audits may be conducted as well, Anthony told Modern Healthcare.

To date, among the most common problems CMS has learned about has been provider failures to meet the requirement that they complete a data security risk assessment, a step also required by HIPAA. When the auditors find that a provider hasn’t done the required data security risk assessment, they could be referred to the HHS Office of Civil Rights for a HIPAA compliance investigation.

Another issue which has turned up frequently has been a lack of adequate documentation that providers have answered some of the “yes or no” questions which are part of Meaningful Use criteria, such as whether their EMR has been tested for clinical data exchange. In that case, providers must be able to document what happened whether or not the test was successful.

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April 29, 2013 I Written By Anne Zieger

Anne Zieger is veteran healthcare consultant and analyst with 20 years of industry experience. Zieger formerly served as editor-in-chief of FierceHealthcare.com and her commentaries have appeared in dozens of international business publications, including Forbes, Business Week and Information Week. She has also contributed content to hundreds of healthcare and health IT organizations, including several Fortune 500 companies.

Tags:CMS Figliozzi and Co. Meaningful Use Audit

Meaningful Use Attestations With Faked Vendor Info?

When providers attest to Meaningful Use Stage 1 compliance, they have to identify the vendor whose EMR they used. But what if a large number of providers were faking this step in an effort to get incentive money that they don’t deserve? That would be a lot of fraud, no?

Well, according to one vendor CEO, this could be happening on a large scale. Mike Jenkins, CEO of cloud-based vendor BuildYourEMR.com, reports that after going over CMS data on Meaningful Use, he found that a whopping 74 percent of providers who attested to using his company’s technology were not his customers.

Jenkins points out that if fraud were actually this common, a full $5.4 billion of the $7.6 billion paid out to providers would have been paid out in error. He admits that there could be something wrong with the CMS data, or that providers selected his company’s product name by accident, but concedes that it’s possible attestation fraud is more common than we think.

I’m not telling you this to suggest that the Meaningful Use program is riddled with fraudulent activity. I’m doubful, in fact, that even a fraction of providers would dare incur the wrath of Medicare by making such a traceable error, much less consciously try to rip the incentive program off.

This does suggest, however, that more healthcare IT people should take a look at the CMS data and go over it themselves, especially EMR vendors. While there may not be a hailstorm of fraud going on, something may be seriously amiss in how CMS collects data or how providers report on their attestation. It’d definitely be good to get ahead of any pending troubles with CMS, for sure.

Few Healthcare Pros Have Attested To Meaningful Use

Despite all of the attention given to Meaningful Use, it seems that eligible healthcare professionals have been relatively slow to achieve compliance. A new report published in the New England Journal of Medicine concludes that just over 12 percent of EPs had attested to the Medicare portion of Meaningful Use as of May 2012, well into the life of the program.

The reasons for this relatively low uptake are complex, but clearly, the EMRs physicians are buying are part of the problem. As a piece in iHealthBeat notes, the National Center for Health Statistics recently found that only 27 percent of office-based physicians had EMRs capable of supporting 13 of the Stage 1 objectives for the MU program. Since EPs have to meet 15 core objectives, plus five of 10 menu options, that leaves the remaining 73 percent of office-based physicians out in the cold.

To calculate uptake of Meaningful Use attestation for the NEJM, researchers with Brigham and Women’s Hospital looked at combined CMS data from April 2011 to May 2012, and GAO estimates of the number of eligible professionals in the U.S.

The researchers found that 12.2 percent of 509,328 eligible professionals had attested to the Medicare portion of the MU program as of May 2012, including 17.8 percent eligible PCPs and 9.8 percent of specialists. PCPs accounted for 44 percent of all Medicare Meaningful Use attestations, the researchers concluded.

Looked at state by state, the median Medicare attestation rate was 7.7 percent of eligible professionals, though rates varied from 1.9 percent in Alaska and 24.2 percent in North Dakota.

These statistics must not be very encouraging ones for CMS, particularly the leaders are ONC. And they certainly make one wonder whether the mass of doctors will end up facing penalties in 2015 rather than making sure they attest to Meaningful Use Stage 1. This should be a real eye-opener for policymakers. As for doctors whose systems simply won’t make the grade, well, this has been called the year of the big EMR switch. I guess we may see even more switching than we expected.

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February 25, 2013 I Written By Anne Zieger

Filed Under: EHR Electronic Health Record Electronic Medical Record EMR EMR Adoption Healthcare Healthcare IT Meaningful Use Research

Tags:Brigham and Women's Hospital CMS Eligible Professionals iHealth Beat Meaningful Use Attestation Meaningful Use Measures

Call to Halt ICD-10 Puts New Angle on Demand for Physicians

The American Medical Association’s most recent call to halt implementation of ICD-10 codes brings to light an interesting angle to the coding story – one that I hadn’t recognized until I read up on just why the AMA has consistently made it known that the switch is a bad idea.

The association believes transitioning to the new, 68,000 codes will place too much of a financial and administrative burden on physicians (especially small practices), and will ultimately force many of them to shut their doors.

Attending education sessions at AHIMA last fall left me with the impression that though learning the new codes and suffering through dual coding wouldn’t be fun, they would ultimately help physicians and hospitals receive proper reimbursement for their services. Yes, there were vendor cheerleaders on many panels, but the logic made sense even to a novice like me.

I realize that physician practices are quite a different kind of beast when it comes to handling administrative tasks, and I can certainly understand how a small practice would feel completely overwhelmed when, as the AMA stated in a letter to CMS, overlapping federal regulations combined with predicted Medicare pay cuts will make switching to ICD-10 a huge difficulty for them.

But I feel as if there’s a catch 22 here. If physicians don’t make the switch, they won’t see the potential financial benefits of more accurate coding. If they do make the switch, they’ll likely face such huge financial strains that they’ll opt to go out of business. Are there any physician readers out there who are cheerleading the ICD-10 switch?

It occurred to me, reading recently about the predicted banner year for physicians seeking hospital employment, that physicians that do decide to close their doors as a result of ICD-10 may contribute to this glut of MDs looking for work.

Perhaps there’s a domino effect waiting to happen – CMS stands firm on the ICD-10 deadline / Physicians work incredibly hard to try and make it happen. / Physicians fail and go out of business, or decide early on that it’s just not worth the trouble and close up shop. / Said physicians seek hospital employment. / There aren’t enough hospital jobs to go around and many MDs are left in the unemployment line.

That’s just one scenario I’ve been mulling over, and of course doesn’t take into consideration the large amount of other challenges facing physicians right now. What’s your take on the ICD-10 and physician staffing situation?

CMS Needs To Tighten Up Meaningful Use Procedures, OIG Says

It looks like members of Congress aren’t the only ones finding fault with how CMS handles Meaningful Use incentives. In fact, HHS’s Office of the Inspector General has concluded that CMS needs to do more to verify that providers have indeed met MU standards both before and after payments get made.

As the OIG notes in its new report, CMS estimates that it will pay out $6.6 billion in incentives between 2011 and 2016. As things stand, the payments will be based on data self-reported by professionals and hospitals. To get a sense of how well this method is working, the OIG reviewed CMS’s incentive program oversight for 2011, as well as analyzing the self-reported data and auditing the agency’s planning docs, regs and guidance for the program.

What did the OIG find? Researchers concluded that CMS faces obstacles to overseeing the EMR incentive program which could end up with its paying providers and hospitals that haven’t fully met Meaningful Use requirements.

More specifically, the OIG concluded that CMS hasn’t put strong prepayment safeguards in place, nor has it good mechanisms for auditing incentive disbursements postpayment. Moreover, ONC requirements for EMR reports might be getting in the way of more accurate incentive payment processes, the report said.

The OIG’s recommendations include having CMS get and review supporting documentation from selected hospitals and professionals before it cuts Meaningful Use checks, a step CMS rejects as imposing too big a burden on providers and slowing the payment process too much. (For the sake of providers that need timely checks, let’s hope it stays that way.) The OIG also recommended that CMS issue specific examples of documentation that can be used to support MU compliance.

Meanwhile, the OIG would like to see ONC change certification requirements for EMRs to make it more likely that they can produce reports for yes/no Meaningful Use measures where possible. It would also like ONC to improve the certification process for EMR technology to make sure EMRs generate accurate reports.

For the most part, the OIG’s recommendations seem reasonable, if not capable of being done overnight. But I’ve got to agree that auditing incentive payments before issuing them would throw a serious kink into the process. Let’s hope the OIG and CMS compromise on something reasonable here.

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December 4, 2012 I Written By Anne Zieger

Filed Under: Certified EHR EHR Electronic Health Record Electronic Medical Record EMR Healthcare Healthcare IT Hospitals Meaningful Use

Tags:CMS HHS Office of the Inspector General ONC

States Lagging Behind in Medicaid Meaningful Use Payments

If I were part of CMS, I’d be pretty annoyed right now: Apparently, state Medicaid programs are beginning to be a wet blanket in the race to get providers up to Meaningful Use standards. According to InformationWeek, a dozen states aren’t yet paying out Medicaid incentives, and some of those haven’t even launched incentive programs yet. Not good news, to say the least.

According to a new post on CMS’s official blog, CMS has handed out Medicare and Medicaid incentives to more than 59,000 eligible professionals and 2,000 hospitals. It also noted that the Medicaid program alone had made more than $1.8 billion in MU incentive payments between January 2011 and the end of last month.

That’s not a bad start, but the slow pace of some Medicaid MU programs is a drag on meeting CMS’s overall goal, which is to have 100,000 providers get MU payments this year.

True, some states are clearly doing their level best: Ohio, which wants to reach 40 percent of eligible providers, Washington, whose goal is 7,000 EPs and hospitals, California, which is trying to get 10,000 providers set up for Medicaid incentives by June; and New York, which hopes to get 6,000 providers get incentive payments in 2012. And 43 states in total have launched a Medicaid incentive program and begun registering applicants, the article reports.

But then there’s the naughty states, which include Hawaii, Idaho, Minnesota, Nebraska, Nevada, New Hampshire, and Virginia — which haven’t launched their Medicaid incentive programs at all. As of December, however, CMS expects (demands?) that all states be making Medicaid incentive payments by June, according to a CMS official quoted in the story.

In the grand scheme of things, I’m pretty confident that Medicare, not Medicaid incentives, are going to drive the train here. That being said, it is worth asking whether the states’ lagging efforts will create serious problems for the MU program. As I see it, it could go either way, but regardless, it’s not a good sign.

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March 30, 2012 I Written By Anne Zieger

Filed Under: EHR Electronic Health Record Electronic Medical Record EMR Healthcare Healthcare IT Hospitals Meaningful Use

Tags:CMS EHR Electronic Health Records Electronic Medical Records EMR InformationWeek Healthcare Meaningful Use Medicaid Medicaid Incentives Medicare

Meaningful Use Stage 2 is Here! Are You Ready?

MU Stage 1 has found some slow-moving and grudging acceptance. According to this news brief from Fierce EMR, a good 42% of providers offices have already attested for MU Stage 1, while another 17% plan to attest within the next year. However, there is also a large number – 39% – who have no plans to do so in the near feature.

The reasons cited include changing technological requirements and budgetary concerns. And in the midst of all this drama, CMS is waiting in the wings with Stage 2 Meaningful Use. The Stage 2 Requirements will be published in the Federal Register on March 4 (Here’s a good meaningful use stage 2 summary for providers).

Are we truly ready for MU Part Deux? I’m not sure we are, and I’m not sure that’s the right question to ask. I’m almost giddy with the promise that MU Stage 2 offers – with greater interchange of information, in standardized formats, and public health reporting realizing its full potential. Maybe a few years into the future, I’ll break a leg skiing in the Swiss Alps and my attending physician there will be able to look up my EHR on his local software. I mean Stage 2 doesn’t come with promises of true international portability of data, but getting past Stage 2 will mean we’re that much closer to true health information flow (if we get state exchanges to effectively exchange information or significant benefits to public health reporting, CMS will declare MU Stage 2 a success.)

Even if you think MU is a load of bunk, you can still be an essential part of the process by participating in the comment stage.

Here’s a direct link to MU Stage 2 rundown published by CMS. The document has details on how you can send CMS your comments.

All comments will go on the regulations.gov website. I’m going to be watching that space in the next two months.

Guest Post: The Case for Modular EHR Over Complete EHR

Dr. Sullivan is a practicing cardiologist who joined DrFirst in 2004, just after completing his term as President of the Massachusetts Medical Society. He is known throughout the healthcare industry as the father of the Continuity of Care Record (“CCR”) and a leader on the future of healthcare technology. He is assisting DrFirst in ensuring that Rcopia continues to add the functionality necessary to maintain its leadership position both in electronic prescribing and in the channel of communication between various sectors of the healthcare community and the physician. Dr. Sullivan is active in organized medical groups at the state and national level, and is both a delegate to the AMA and the Chairperson of their Council on Medical Service as well as past Co-Chair of the Physicians EHR Consortium.

The buzz surrounding Electronic Health Records (EHR) is nothing short of constant. The daunting task of selection, purchase and implementation is quite confusing, technical, and expensive, with many physicians, clinics and health systems uncertain of their needs and questioning how the technology is going to impact the way they practice medicine and their bottom line. It’s all about workflow and productivity.

More recently, Providers are faced with the intimidating task of deciding which kind of system to install. There are all inclusive systems, often referred to as fully paperless or standard EHRs and there are so called a la carte systems known as modular EHRs.

The Case for Modular

Modular EHR systems allow providers to take a stepping stone approach to health IT clinical documentation and order writing, by choosing the tools and functions which make the most sense in their practices and clinics; improving specialized workflow and efficiency. Going the modular route can gradually ease the provider and the office staff into a more paperless environment without having to make a full and often-times difficult transition to a fully paperless workspace.

There is need for caution however. The sheer volume of modules available can make selecting appropriate ones an overwhelming task. Not only do clinicians need to be wary of which modules they are choosing, but also what functions have been certified by an authorized organization.

By combining specific modular systems, it can become “qualified,” making the user eligible for the monetary reimbursements set forth by Title IV of the American Recovery and Reinvestment Act of 2009 (ARRA).

At DrFirst, our Rcopia-MU^TMhas taken all of the guess work out of this process and is a completely certified Modular EHR that physicians can implement and start earning incentive money directly out-of-the-box.

The implementation of a complete EHR system can be confusing and time consuming. Herein lays some distinct advantages of implementing a modular EHR. Practices that have already implemented e-prescribing or registry modules may not need to relearn a different system, or move their data from one to another (as long as the current module is certified).

Providers who are considering going the modular route can check the certification status of their options at Certified Health IT Products List. The cost for a modular approach is often much less expensive and providers can select the modules from various vendors to meet their financial and practice-based needs. Upon implementation, providers must show they’re using certified EHR technology in measureable ways to receive their incentive monies from the Federal Government. With this very high ROI, many providers see the advantage of using the modular approach to postpone the decision process in selecting a complete EHR and yet at the same time earn Meaningful Use incentive money to put towards the cost of the much more expensive system.

According to the Centers for Medicare and Medicaid Services, doctors who have not adopted an EHR (either modular or complete) by 2015 will be penalized by Medicare — a 1% penalty to begin, then up to 3% within three years. Many providers are banking on the reimbursement that has been made available by the ARRA to help offset the initial costs.

What is your practice considering, complete EHR or modular? Do you see benefits of one over the other?

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November 30, 2011 I Written By John Lynn

John Lynn is the Founder of the HealthcareScene.com blog network which currently consists of 15 blogs containing almost 5000 articles with John having written over 2000 of the articles himself. These EMR and Healthcare IT related articles have been viewed over 9.3 million times. John also recently launched two new companies: InfluentialNetworks.com and Physia.com, and is an advisor to docBeat. John is highly involved in social media, and in addition to his blogs can also be found on Twitter: @techguy and @ehrandhit.

Filed Under: ARRA Certified EHR EHR Electronic Health Record Electronic Medical Record EMR Healthcare IT Meaningful Use

Tags:AMA CCHIT CCR CMS Complete EHR Certification Complete EHR Software Continuity of Care Record Dr. Sullivan DrFirst HITECH Massachusetts Medical Society Modular EHR Certification Modular EHR Software ONC Rcopia-MU

Haven’t Been Paid your EHR Incentive Money Yet? One Possible Reason Why

The CMS FAQ site has a great question up that I have a feeling a number of doctors will be interested in knowing the answer to:
I am an eligible professional (EP) who has successfully attested for the Medicare Electronic Health Record (EHR) Incentive Program, so why haven’t I received my incentive payment yet?

Here’s their answer:

For EPs, incentive payments for the Medicare EHR Incentive Program will be made approximately four to eight weeks after an EP successfully attests that they have demonstrated meaningful use of certified EHR technology. However, EPs will not receive incentive payments within that timeframe if they have not yet met the threshold for allowed charges for covered professional services furnished by the EP during the year.

The Medicare EHR incentive payments to EPs are based on 75% of the estimated allowed charges for covered professional services furnished by the EP during the entire payment year. Therefore, to receive the maximum incentive payment of $18,000 for the first year of participation in 2011 or 2012, the EP must accumulate $24,000 in allowed charges. If the EP has not met the $24,000 threshold in allowed charges at the time of attestation, CMS will hold the incentive payment until l the EP meets the $24,000 threshold in order to maximize the amount of the EHR incentive payment the EP receives. If the EP still has not met the $24,000 threshold in allowed charges by the end of calendar year, CMS expects to issue an incentive payment for the EP in March 2012 (allowing 60 days after the end of the 2011 calendar year for all pending claims to be processed).

Payments to Medicare EPs will be made to the taxpayer identification number (TIN) selected at the time of registration, through the same channels their claims payments are made. The form of payment (electronic funds transfer or check) will be the same as claims payments.

Bonus payments for EPs who practice predominantly in a geographic Health Professional Shortage Area (HPSA) will be made as separate lump-sum payments no later than 120 days after the end of the calendar year for which the EP was eligible for the bonus payment.

For more information about the Medicare and Medicaid EHR Incentive Program, please visit http://www.cms.gov/EHRIncentivePrograms.

This is actually something that I’ve written about before (probably on EMR and HIPAA), but I have a feeling many people weren’t looking at the details to realize why they aren’t getting their incentive money. You have to wait until you have enough Medicare Allowable Charges before they’ll pay you. I think this is a smart plan I do find it interesting that there were some clinics that had enough allowable charges in 3 months to receive the full EHR incentive money right away. I’d love to see some stats on medicare allowable charges per provider. Would be interesting to see how this aspect of the EHR incentive program affects Medicare providers.

Either way, hopefully this information will help someone who is wondering where they EHR incentive money is. Thanks to @jimtate for tweeting the FAQ and reminding me of this part of the program.

Health IT Expenses Burden ACO Startups, But CMS Doesn’t Get It

A new study sponsored by the American Hospital Association has concluded that developing an Accountable Care Organization is likely to be substantially more expensive than CMS has projected. Not surprisingly, the AHA expects buying and managing EMRs and clinician decision support systems to be a major percentage of the added expense.

CMS has estimated it will cost an average of $1.8 million to start and sustain an ACO. But the AHA dismisses that number as far short of the mark. Its own research, conducted by McManis Consulting, concluded that the actual startup and first-year costs for ACOs range from $11.6 million for a 200-bed, one-hospital system to $26.1 million for a 1,200 bed, five-hospital system.

The AHA estimates that hospitals will spend anywhere from $2 million to $7 million to buy an EMR, and hundreds of thousands to integrate the system and build a health information exchange. Not only that, health systems are likely to spend anywhere from $1.5 million to $3.9 million per year to maintain the EMR, manage the integration process and keep building out the HIE. (My instinct is that the study’s estimates of systems integration and HIE linkages are rather low; check out page two of the report and let me know what you think.)

If the AHA has it right — and I suspect it does — something is out of order here. It’s hard for me to imagine how the agency could underestimate health IT costs so significantly, unless there’s some political game afoot here.

I’m not surprised to read that HIT costs are just as heavy a burden as recruiting, managing and and supporting affiliated physicians. And I’m pretty sure that hospital CIOs aren’t kidding themselves on this front either.

Somehow, though, the Medicare folks have made some rather flawed assumptions and embedded them in the proposed Medicare Shared Savings Program for ACOs. If you agree that CMS is on the wrong foot here, I encourage you to submit comments on the proposed rule. (See the beginning of the document for how to file those comments.) You have until June 6, so have at it!

CMS Plans To Audit 5 Percent of Meaningful Use Participants

Meaningful Use Attestations With Faked Vendor Info?

Few Healthcare Pros Have Attested To Meaningful Use

Call to Halt ICD-10 Puts New Angle on Demand for Physicians

CMS Needs To Tighten Up Meaningful Use Procedures, OIG Says

States Lagging Behind in Medicaid Meaningful Use Payments

Meaningful Use Stage 2 is Here! Are You Ready?

Guest Post: The Case for Modular EHR Over Complete EHR

Haven’t Been Paid your EHR Incentive Money Yet? One Possible Reason Why

Health IT Expenses Burden ACO Startups, But CMS Doesn’t Get It

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