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AAA for MU: Roadside Assistance for the EHR Incentive Program

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Much has changed in 2014 for Meaningful Use (MU)—and been changed back again, temporarily. Many practices have questions about how to participate effectively. Physicians and practice managers are …

Much has changed in 2014 for Meaningful Use (MU)—and been changed back again, temporarily. Many practices have questions about how to participate effectively. Physicians and practice managers are concerned about putting undo burden on themselves and other staff, tracking and reporting accurately, and avoiding an audit. Find out how to get the incentive, avoid the penalty, and participate in MU through lessons learned from other EHR users.
 
Meaningful use expert Barbara Drury will shares her AAA advice:
· A(dopt): Experiences learned from MU1 and MU2 EHR users
· A(ttest): Issues to address during and after yearly attestations
· A(udit): Housekeeping and preparation experiences to date
· Quality opportunities beyond MU

This is your chance to make sure you are doing MU right—from Adopting through Attestation and Audits!

Barbara Drury, BA, FHIMSS, is President of Pricare Inc., an independent health information technology consulting firm founded in 1982. She frequently lectures and writes about the impact of office-based computer systems and electronic medical record systems for entities such as medical societies, healthcare organizations, and others. Ms. Drury served as an appointee to the ONC's Technical Expert Panel on Unintended Consequences of HIT Adoption. She has achieved Fellow Status with the Healthcare Information and Management Systems Society (HIMSS) and has served on the HIMSS Public Policy Committee and the Davies Ambulatory Award Committee. Ms. Drury is also a frequent speaker at the HIMSS Annual Conference and is the recipient of the December 2004 and the April 2009 Spirit of HIMSS award.

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  • 1. PAGE 1 KAREO | @GoKareo; #KareoTip AAA for MU: Roadside Assistance for the EHR Incentive Program
  • 2. PAGE 2 KAREO | @GoKareo; #KareoTip Our Schedule for Today… 1 Introduction & Welcome Barbara 2 AAA for MU: Roadside Assistance for the EHR Incentive Program 3 Discover Kareo’s Role 4 Answer Questions
  • 3. PAGE 3 KAREO | @GoKareo; #KareoTip Your Hosts Today… Barbara Drury, BA, FHIMSS, & President, Pricare, Inc. Lea Chatham Content Marketing Manager, Kareo
  • 4. PAGE 4 KAREO | @GoKareo; #KareoTip Participate via Social Facebook.com/GoKareo Twitter.com/GoKareo http://kareo.ly/kareogroup We’ll be live tweeting during today’s webinar! How to participate: 1. Follow @GoKareo on Twitter 2. Follow @LeaChatham on Twitter 3. Search for #KareoTip 4. Join the conversation using #KareoTip 5. Join Building Best Practices group on LinkedIn
  • 5. PAGE 5 KAREO | @GoKareo; #KareoTip Barbara Drury, BA, FHIMSS  Health information technology consultant  Speaks and writes on office-based computer systems for groups like HIMSS, ABA, MGMA, PAHCOM & AHIMA  Appointee to the ONC’s Technical Expert Panel on Unintended Consequences of HIT adoption  Fellow of the Healthcare Information and Management Systems Society  EHR Risk Manager for The Doctors Company and COPIC Insurance Co. Barbara Drury, BA, FHIMSS President, Pricare, Inc. bdrury28@earthlink.net
  • 6. PAGE 6 KAREO | @GoKareo; #KareoTip Our Schedule for Today… 1 Introduction & Welcome Barbara 2 AAA for MU: Roadside Assistance for the EHR Incentive Program 3 Discover Kareo’s Role 4 Answer Questions
  • 7. PAGE 7 KAREO | @GoKareo; #KareoTip AAA for MU! Acute Anxiety Attack? Advanced Amphibious Assault? Amateur Astronomers Association? 85 other definitions for “AAA”, but today: –Adopt –Attest –Audit
  • 8. PAGE 8 KAREO | @GoKareo; #KareoTip Agenda:  Review of key definitions and concepts of the EHR Incentive Program  Adopt: Experiences learned from MU1 and MU2 EHR users  Attest: Issues to address during and after yearly attestations  Audit: Experiences to date  Quality opportunities beyond MU
  • 9. PAGE 9 KAREO | @GoKareo; #KareoTip Who May Earn the Incentive?  EP = eligible professional (maximum was MCR=$44k, MCD = $63,750)  Individual physicians, not practices  Doctors, (mid-levels only for MCD and rural)  OFFICE encounters only, with  Max of one per day per patient per EP  May include or exclude “others on behalf of EP”
  • 10. PAGE 10 KAREO | @GoKareo; #KareoTip Ready or not, here’s a quick dip in the MU alphabet soup!
  • 11. PAGE 11 KAREO | @GoKareo; #KareoTip Incentive Program Lingo for EPs  CALENDAR Year: Jan 1 thru Dec 31.  STAGE: MU1, MU2, MU3  Stage YEAR: Yr1, Yr2  A Yr3-only applies to early adopters each stage  REPORTING Period: “any 90 days”, Calendar Quarter, 365 days.  PROGRAM Year: MCR 1 to 6. MCD 1 to 10.  Change incentive program once—from MCR to MCD or MCD to MCR, next ‘new’ year can’t be Yr1
  • 12. PAGE 12 KAREO | @GoKareo; #KareoTip Meaningful Use Lingo, part 1  MEASURE: a calculation, or Yes/No or Exclusion.  CORE or MENU SET means  Core = all measures are required  Menu Set = you can pick (with some pre-set requirements)  OBJECTIVE: description of what you need to ‘do’  THRESHOLD: minimum % (numerator/denominator)  Note that some OBJECTIVES have multiple MEASURES with different THRESHOLD %s.
  • 13. PAGE 13 KAREO | @GoKareo; #KareoTip Meaningful Use Lingo, part 2  EXCLUSION: doesn’t apply. Some MEASURES have NO Exclusions. Not the same as “exempt”.  Measure #s changed between 2011, 2013, 2014 so focus on the TITLE of the MEASURE, not #s.  MEANINGFUL USER: Meet all THRESHOLDs required for CORE and MENU OBJECTIVES.  EXEMPT from the EHR Incentive Program is limited to very few specialties.
  • 14. PAGE 14 KAREO | @GoKareo; #KareoTip 14 MU1 at 2014 MU2 at 2014 CPOE CPOE Drug Interactions Drug Interactions Problem List Problem List E-Prescribing E-Prescribing & formulary inquiry Medication List Medication List Allergy List Allergy List Demographics Demographics Vitals Vitals Smoking Status Smoking Status Clinical Decision Support (CDS) Clinical Decision Support (CDS) View/Download/ Transmit (VDT) View/Download/ Transmit (VDT) Office Visit Summaries Office Visit Summaries Security Risk Assessment Security Risk Assessment Formularies Formularies Structured Lab Results Structured Lab Results Patient List Patient List Reminders Reminders Patient Education Patient Education INBOUND Medication Reconciliation INBOUND Medication Reconciliation OUTBOUND Transitions of Care OUTBOUND Transitions of Care Immunization Registry (according to law) Immunization Registry (except where prohibited by law) Syndromic Surveillance Reporting (according to law) Syndromic Surveillance Reporting (except where prohibited by law) Secure Messaging Secure Messaging Electronic Notes in EHR Electronic Notes in EHR Imaging Results Imaging Results Family Health History Family Health History Cancer Registry Cancer Registry (except where prohibited by law) Specialty Registry Specialty Registry (except where prohibited by law) MU1 at 2014 MU2 at 2014 CORE MENU Add, Delete or Incorporate
  • 15. PAGE 15 KAREO | @GoKareo; #KareoTip 15 MU1 at 2014 MU2 at 2014 Exclusions, for MU1 in 2014 Exclusions, for MU2 in 2014 Medication List Medication List No exclusion See "VDT", "OUTBOUND Transitions of Care" Allergy List Allergy List No exclusion See "VDT", "OUTBOUND Transitions of Care" Demographics Demographics No exclusion No exclusion Clinical Decision Support (CDS) Clinical Decision Support (CDS) No exclusion No exclusion for 5 rules on 4 CQMs. Excl #2 = less than 100 prescritions, then drug-drug interaction CDS not required. View/Download/ Transmit (VDT) View/Download/ Transmit (VDT) Any EP who does not order or create any of the patient data other than name. Excl #1 = Any EP who does not order or create any of the patient data other than name, Excl #2 = EP in county less than 50% of households without 3 mbps. Office Visit Summaries Office Visit Summaries Any EP who has no office visits during the reporting period. Any EP who has no office visits during the reporting period. Security Risk Assessment Security Risk Assessment No exclusion No exclusion Formularies Formularies Any EP who writes fewer than 100 prescriptions. Must enter 0 See "e-Prescribing & formulary inquiry" Structured Lab Results Structured Lab Results Any EP who orders no lab tests that have +/- or numeric during period. Any EP who orders no lab tests that have +/- or numeric during period. Patient List Patient List No exclusion No exclusion Reminders Reminders EP has no patients over 65 or under 5 in the EHR EP has no office visits in the 24 months before EHR reporting period. Patient Education Patient Education No exclusion EP has no office visits in the 24 months before EHR reporting period. INBOUND Medication Reconciliation INBOUND Medication Reconciliation EP with no inbound patients during the reporting period EP with no inbound patients during the reporting period OUTBOUND Transitions of Care OUTBOUND Transitions of Care EP with no transfers out or referrals out EP with transfers out or referrals out less than 100 times during the reporting period. Immunization Registry (according to law) Immunization Registry (except where prohibited by law) EP who administers none or registry not capable. Excl #1 EP who administers none, Excl #2 = registry not capable, Excl #3 = registry is not timely, Excl #4 = enrollment not timely. Syndromic Surveillance Reporting (according to law) Syndromic Surveillance Reporting (except where prohibited by law) EP does not collect reportable data, registry not capable, or prohibited EP does not collect reportable data, registry not capable, or prohibited Secure Messaging Secure Messaging New to MU2 Excl #1 = Any EP who does not order or create any of the patient data other than name, Excl #2 = EP in county less than 50% of households without 3 mbps. Electronic Notes in EHR Electronic Notes in EHR New to MU2 Any EP who has no office visits during the reporting period. Exclusions also changed: - Dependencies - More specificity - Incorporated as part of another Partial List displayed
  • 16. PAGE 16 KAREO | @GoKareo; #KareoTip Your MU “world” could look like this: 16 EP New MCR • CY 2014 • MU1-2013 • Yr1 • Any 90 days • 1st year EP Lisa • CY 2013 • MU1 • Yr3 • 365 days • 3rd year EP Betsy • CY 2013 • MU1 • Yr1 • Any 90 days • 1st year EP Lisa • CY 2012 • MU1 • Yr2 • 365 days • 2nd year EP Lisa • CY 2011 • MU1 • Yr1 • Any 90 days • 1st year EP Lisa • CY 2014 • MU2 • Yr1 • Quarter • 4th year EP Betsy • CY 2014 • MU1-2013 • Yr2 • Quarter • 2nd year EP Tom • CY 2013 • No MU • 3rd year EP Tom • CY 2012 • No MU • 2nd year EP Tom • CY 2011 • MU1 • Yr1 • Any 90 days • 1st year EP Tom • CY 2014 • MU1-2013 • Yr2 • Quarter • 4th year
  • 17. PAGE 17 KAREO | @GoKareo; #KareoTip Your Vendor’s Certification “world”:  Certification criteria = vendor products  Most align with MU measures  EHR Certification also defines data standards  A testing body uses your vendor’s ‘generic’ configuration but not necessarily your EPs setup. CY 2011 use 2011 Edition to calculate MU1 and up to 44 CQMs CY 2012 use 2011 Edition to calculate MU1 and up to 44 CQMs CY 2013 use 2011 Edition with 2013 changes to calculate MU1 and up to 44 CQMs CY 2014 use 2014 Edition with 2013 changes to calculate MU1, calculate MU2 and up to 64 CQMs CY 2015 use 2014 Edition with 2013 changes to calculate MU1, calculate MU2 and up to 64 CQMs and optional 2015 certification criteria
  • 18. PAGE 18 KAREO | @GoKareo; #KareoTip And the “Editions” are: 18 EP New MCR • CY 2014 • MU1 • Yr1 • Any 90 days • 1st year EP Lisa • CY 2013 • MU1 • Yr3 • 365 days • 3rd year EP Betsy • CY 2013 • MU1 • Yr1 • Any 90 days • 1st year EP Lisa • CY 2012 • MU1 • Yr2 • 365 days • 2nd year EP Lisa • CY 2011 • MU1 • Yr1 • Any 90 days • 1st year EP Lisa • CY 2014 • MU2 • Yr1 • Quarter • 4th year EP Betsy • CY 2014 • MU1 • Yr2 • Quarter • 2nd year EP Tom • CY 2013 • No MU • 3rd year EP Tom • CY 2012 • No MU • 2nd year EP Tom • CY 2011 • MU1 • Yr1 • Any 90 days • 1st year EP Tom • CY 2014 • MU1 • Yr2 • Quarter • 4th year
  • 19. PAGE 19 KAREO | @GoKareo; #KareoTip Would you rather munch a ‘carrot’ or a ‘stick’?
  • 20. PAGE 20 KAREO | @GoKareo; #KareoTip Stick (Medicare PFS Penalty)  Has a two-year look back period.  2015 PFS looks at 2013 MU,  2016, PFS looks at 2014 MU,  2017 PFS looks at 2015 MU, and so on  Begins Jan 1, 2015 and if not a MU, goes from  100% PFS in 2014 to  99% in 2015,  98% in 2016,  97% in 2017.  Applies to entire PFS, not just office encounters
  • 21. PAGE 21 KAREO | @GoKareo; #KareoTip Why Be a Meaningful User in 2014?  (carrot) Earn the incentive for 2014  (carrot) NOW is the last year to start MU to earn any MCR incentive in 2015 and 2016.  (stick) If not before Oct 1st, then 2015 MCR penalty  (stick) If not in 2014, then a 2016 MCR penalty  Discussions around the water cooler:  It’s cheaper to take the penalty  I hate leaving that much money on the table  My patients want electronic access  The hospital will buy us and we’ll be forced to use theirs  It depends on …
  • 22. PAGE 22 KAREO | @GoKareo; #KareoTip From 12/18/13 ONC webinar May 2014 NPRM changed December 2013’s schedule. Waiting for “Final Rule”, perhaps before Labor Day, so it’s going to change AGAIN!
  • 23. PAGE 23 KAREO | @GoKareo; #KareoTip Agenda:  Review of key definitions and concepts of the EHR Incentive Program  Adopt: Experiences learned from MU1 and MU2 EHR users  Attest: Issues to address during and after yearly attestations  Audit: Experiences to date  Quality opportunities beyond MU
  • 24. PAGE 24 KAREO | @GoKareo; #KareoTip It wasn’t pretty and we made it, but we had some surprises along the way!
  • 25. PAGE 25 KAREO | @GoKareo; #KareoTip EHR Setup Impacts Calculations  Rendering or billing—with mid-levels or ancillary  Free text can’t be counted by any EHRs  EHR’s ‘right’ boxes aren’t necessarily obvious or usually done by you  Race, ethnicity and language = front desk  Pharmacy = front desk or MA/RN staff  Transition of care INBOUND = front desk, not MD  Medication reconciliation = MA/RN/MD  Diagnoses code for claim not same as problem list  Prescription, transmitted, not same as medication list
  • 26. PAGE 26 KAREO | @GoKareo; #KareoTip Detective Work May Be Required  “In the beginning…” run EP’s MU report often  Start running MU reports  Make corrections to workflow or behaviors  Show each EP team (MD+staff) how to run their personal report  “When” the MU report updates varies by product  In real time, as soon as ‘saved’, or posted  Overnight processing required, or month end process + 10 days  MU calculations done outside of your data base, an export, calculated elsewhere and returned to you as ‘finished’ documents  Not easy to find exactly where the numbers came from  Keep after it until you believe the numbers and the ‘next’ person can understand as well
  • 27. PAGE 27 KAREO | @GoKareo; #KareoTip For some things, the EHR just didn’t fit us, so we figured out a work- around.
  • 28. PAGE 28 KAREO | @GoKareo; #KareoTip An EHR for MU Might be a Mismatch  Your expectations, specialty, training, workflow…  If you’re thinking about changing EHRs, plan for:  Data conversion  Records retention  MU Reporting Periods, especially if yours is 365 days – Get a good reporting period out of old before changing. – Timing so ‘next’ reporting period is all new EHR
  • 29. PAGE 29 KAREO | @GoKareo; #KareoTip Areas of Compromise  CPOE – e-orders out is less common. – Impact: drop-to-paper orders with manual matching of e-results  Interfaces – between medical devices and EHR = two parties – Impact: extra steps to ‘use’ interfaces (spot vitals, ultrasound, EKG, etc.)  Quality Measures – different programs in different places – Impact: double work for staff (often the MD)  MU CQMs must come from an EHR that has been certified to calculate the CQMs you report on – Impact: Busy-work versus CQMs meaningful to your specialty, i.e. Dermatology must choose “Functional Status for Hip Replacement” based on CQMs chosen by the dermatologist’s EHR vendor.
  • 30. PAGE 30 KAREO | @GoKareo; #KareoTip Patient Portal is a Big Deal  CMS changes to Stage 1 in FR for Stage 2 MU1 and MU2: Online access for patients within 4 business days after available to EP “Access” for patient is key. Does not require any action by the patient, but requires that: – The patient has necessary Information which is defined as “website address, username, password, instructions for logging in”.  Stage 2 is only stage that requires patient action:  View, download, or transmit-to-3rd-party.
  • 31. PAGE 31 KAREO | @GoKareo; #KareoTip VDT Notes;  Retains the “harmful to the patient” caveat  All contributing EPs who saw this patient during the reporting period may take credit for:  “online access available” / MU1 & MU2  “VTD” / MU2 if patient VTDs ‘any’ contributed by any EP.  CMS says “charging the patient a fee is not appropriate”
  • 32. PAGE 32 KAREO | @GoKareo; #KareoTip Roles for Rolling Out the Portal Impact to staff and workflow  Who is going to ‘enroll’ the patient  Who is going to remind the patient to ‘enroll’  Who is going to monitor inbound communications  Who will teach patients what is appropriate use  Who will discharge patients for inappropriate use  Who will teach patients responsibility for the privacy of their data, sharing of passwords, printed copies, etc.
  • 33. PAGE 33 KAREO | @GoKareo; #KareoTip “It’s the patient’s record” to VDT:  No longer acceptable: – It’s too complicated; the patient won’t get what I said – I don’t want another provider to read my note – I’m the only one that knows what I meant – I don’t want to become an editor of my own words – I’m the doctor and my recommendation is best  New mantra = “It’s my words for the world to read, so I better read it before I save and sign!”
  • 34. PAGE 34 KAREO | @GoKareo; #KareoTip We’re on the Same Path, but….  EPs will be at different Stages  EPs will be in different years of the MU Stage  EPs may require different Reporting Periods  EPs may choose different exclusions  EPs can choose different Menu Measures  EPs can choose different CQMs  And, the certified EHR must be able to handle all!  And pending the CMS NPRM on Hardship Exemptions, EPs might be using different Editions
  • 35. PAGE 35 KAREO | @GoKareo; #KareoTip Agenda:  Review of key definitions and concepts of the EHR Incentive Program  Adopt: Experiences learned from MU1 and MU2 EHR users  Attest: Issues to address during and after yearly attestations  Audit: Experiences to date  Quality opportunities beyond MU
  • 36. PAGE 36 KAREO | @GoKareo; #KareoTip Attestation (starts with Registration)  There is a registration process before you can attest.  Attestation: – End of reporting period – Workbook (Stage 1 EP Attestation Worksheet , CMS site) – Must ‘submit’ and CMS must ‘accept’ – On-behalf-of is permitted (review with providers before) – You enter numerator/denominator and CMS calculates % – You may change your mind but must re-enter, using a different period with different numbers – CMS ‘accepts’ and ‘locks for payment’, attestation is done
  • 37. PAGE 37 KAREO | @GoKareo; #KareoTip CMS Has Guides – worth reading (75 pages)
  • 38. PAGE 38 KAREO | @GoKareo; #KareoTip $16000 in Allowable Charges Required before Incentive Paid Expected Incentive Reporting Period Attestation Accepted by CMS CMS Has Paid Incentive? Allowable Q1 Charges Allowable Q2 Charges Allowable Q3 Charges Allowable Q4 Charges Charges at ATTESTATION CMS Pay Date (appx) MU1, Y1 (2011, or 2012, or 2013, OR 2014) $12,000 = 75% of $16,000 allowable 2014, Jan 5 to Apr 5, any 90 days for 1st year of program April 15, 2014 Not at 7/24/2014 $ 5,000 $ 6,000 tbd tbd $ 11,000 60 days after $16k clears MU1, Y2 occurring in 2014 $12,000 = 75% of $16,000 allowable 2014, Q3 October 20, 2014 Yes on Nov 5, 2014 $ 7,000 $ 7,000 $ 7,000 $ 7,000 $ 21,000 As soon as processed MU1, Y2 occurring in any year NOT 2014, i.e. 2013 $12,000 = 75% of $16,000 allowable 2013, 365 days January 18, 2014 Yes on Mar 3, 2014 $ 6,000 $ 7,000 $ 6,000 $ 7,000 $ 19,000 Within 60 days of attestation or year end MU1, Y2 in 2013 $12,000 = 75% of $16,000 allowable 2013, 365 days May 22, 2014 None will be paid $ 6,000 $ 7,000 $ 6,000 $ 7,000 $ 26,000 No payment will be made for 2013 year For Medicare: Show me the money! Incentive is a ‘max’, not a guarantee 75% allowable charges, capped max for your year.
  • 39. PAGE 39 KAREO | @GoKareo; #KareoTip Attestation Basics  Yr1 Attestation starts the MCR “Program Year” clock  Meet the measure at “80% or more”, systems round DOWN, not up  79.6% = 79%, measure of 80% NOT met, no incentive  80.6% = 80%, measure of 80% met, earn incentive  Designate ‘who’ gets the money on EP’s behalf, must decide BEFORE CMS registration. Employed MDs?  Money is taxable, provider will receive a 1099.
  • 40. PAGE 40 KAREO | @GoKareo; #KareoTip About Medicaid  Medicaid is different.  First year for Medicaid may be AIU or MU  AIU = meet visit%, no MU measure thresholds required  MU = a “meaningful user “ for Year 1 only if visit % AND Measures/thresholds are met Percents for visit counts round DOWN, not up  29.7% Medicaid visits = 29%, not eligible, 30.7% Medicaid visits = 30%, yes, eligible for incentive  AIU Incentive (adopt/implement/upgrade) may be documented and requested AFTER the visit count met.  Registration starts with CMS and if MCD, links to state  Medicaid attestation tail = 60, 90, 120 days after last day of reporting period and varies by state
  • 41. PAGE 41 KAREO | @GoKareo; #KareoTip State Medicaid Requirements Vary  CMS/ONC approved each state’s plan  Some variations noted (really!)  Provide an excel file with EP’s Medicaid #, patient’s MCD #, DOS and source of payment or no charge  Itemize which visits were billed incident-to  MCD patients from multiple states will be validated by the state you’re claiming, may delay payment  Zero pay visits must be isolated for audit  Name of patient’s pharmacy  Name of person completing Security Risk Assessment  Will likely require custom work by EHR vendor
  • 42. PAGE 42 KAREO | @GoKareo; #KareoTip Did you know…  For Medicare Incentive Program  Carrot is earning the incentive in 2014, either Q1, Q2, Q3, Q4 or if MU1, Yr1, any 90 days  Stick is if not an MU in 2013, and not an MU in 2014 before October 1st (Q1, Q2, Q3), then 1% Medicare PFS begins Jan 1, 2015  For Medicaid Incentive Program  Carrot is AIU or MU between 2011 and 2021  No Stick for EP from Medicaid if sees no Medicare patients  For EP choosing Medicaid but sees MCD and MCR  Medicaid AIU (not MU) carrot in 2014 • Not an MU in 2014 for MCD Program, stick is Medicare 1% penalty in 2015  Medicaid MU (not AIU) carrot in 2014 • Considered an MU in 2014, therefore NO Medicare PFS penalty in 2015
  • 43. PAGE 43 KAREO | @GoKareo; #KareoTip Dotting the “I”s and crossing the “t”s  If certified EHR does the calculations and you use those numbers, CMS will not penalize you for bad data.  If you export to excel to manipulate what the EHR calculated, that is a risk. Keep all exported files and reports.  Check the math. Attestation does % after entry. Don’t be surprised by a miscalculation  EP’s MU Report should be printed, showing all data  Product Name/Version  Date period  Date of report  EH or EP name  If your product doesn’t, then add screen prints of the reporting setup screen as the ‘first’ page of the report.
  • 44. PAGE 44 KAREO | @GoKareo; #KareoTip What if you want to switch?  One switch allowed, either way  Dr. Lisa, 2014 is her 3rd year of the Incentive Program  2012 MCD, AIU $  2013 MCD, MU1, Yr1, $  2014 MCR, MU1, Yr2, $  2015 MCR, MU2, Yr1, $  2016 MCR, MU2, Yr2, $  Has until 2016 to earn MCR Incentives  Dr. Tom, 2014 is his 3rd year of the Incentive Program  2012 MCR, MU1, Yr1, $  2013 MCR, MU1, Yr2, $  2014 MCD, MU2, Yr1, $ (no AIU money, jumps in 3rd year MCD, $8500)  May earn $8500 up to 3 more years between now and 2021.
  • 45. PAGE 45 KAREO | @GoKareo; #KareoTip Agenda:  Review of key definitions and concepts of the EHR Incentive Program  Adopt: Experiences learned from MU1 and MU2 EHR users  Attest: Issues to address during and after yearly attestations  Audit: Experiences to date  Quality opportunities beyond MU
  • 46. PAGE 46 KAREO | @GoKareo; #KareoTip Audits Mandated by Regulation  Figliozzi and Company: CMS designated auditor for MCR. States have separate auditors for MCD  Random and targeted (triggered by questionable data)  Initial contact will be email letter to the email address in CMS attestation system  Initial review will be remote, of requested documentation  Potential to come on site  Potential to see EHR in action, generate reports, alerts, etc.  Any single ‘oops’ of the Core and Menu and CMS will fail the audit, recoup the payment for the audited year.  See CMS “EHR Incentive Program Supporting Documentation for Audits” – 5 page pdf
  • 47. PAGE 47 KAREO | @GoKareo; #KareoTip Audit “abnormal data” or “red flag”  Audits may be ‘targeted’ but random  Painful audit activity seen:  Attesting for period when the EHR was not certified  Generate reports with 0’s after attesting with numbers  Original on-behalf-of staff now gone, no one knows where documentation is, no records, fails audit  Using billing system to generate data for calculations  Achieving 100% of any/many measures
  • 48. PAGE 48 KAREO | @GoKareo; #KareoTip Security Risk Assessment  Big ‘red flag’ during audits, high failure rate  No exclusion for MU1 or MU2, conduct or review  Conduct is 1st year of Incentive Program for EP  Review or update is each subsequent reporting period  Each EP should be provided a copy for review, initial to indicate review  EP must review and update or indicate no update required this period.  If EPs attest for different periods, the review must be during EP’s period  Produce copy of Security Risk Assessment  Recommendations  Your response to each recommendation (action plan)  You are responsible for Risk Assessment, not your vendor.  Checklists not sufficient, assessment templates an option
  • 49. PAGE 49 KAREO | @GoKareo; #KareoTip 6 year period starts 6 year period starts Audit Recap in Pictures EP’s Reporting Period Attestation by EP or on-behalf- of MCRPayment Post- Payment Audit Initiated Pass/Fail, Appeal MCRRecoup $$$ EP’s Reporting Period Attestation by EP or on-behalf- of MCRPayment Pre- Payment Audit Initiated MCRDenies $$$ OR NoMCR Adjustment OR Pass/Fail, Appeal
  • 50. PAGE 50 KAREO | @GoKareo; #KareoTip Internal Audit Process Audit letter emailed Audit letter received Requested documents provided Requested documents reviewed Onsite review date set Figliozzi on site, Further review Determination Letter emailed. Fail = demand Appeal process (option)
  • 51. PAGE 51 KAREO | @GoKareo; #KareoTip Documentation Details for Audit  Backup copies of paper reports (in paper and pdf)  Screen shots of any measure that is a yes/no. Redact PHI.  Details on the security risk assessment including written account of steps taken, not taken and why  Indication that the EP getting the $ has read it!  If the CMS/ONC FAQs directed you how to handle a unique situation, keep a copy of the FAQ.  Audits for AIU for MCD (not MU) are different, see state  If upgrading, evidence of staff training, vendor invoices, etc.  If upgrading, may not have a new ‘contract’ or ‘SLSA’, but may have an increase in costs that might be an invoice or a revised SLS  Audits began 2013 to audit 2011 EPs, through 2022.
  • 52. PAGE 52 KAREO | @GoKareo; #KareoTip Tips  Don’t ignore correspondence – Check junk mail, absent staff person’s email.  Six years is a long time: two people should know how to access the Registration/Attestation website and where all the electronic and paper documentation is retained.  Instructions for finding documentation should be stored securely but not invisible.  If asked, could you access the EHR you were using two years ago (or 3, 4, or 5 years ago) and reproduce exactly your numbers for your Reporting Period?  Consider screen shots or audit logs as evidence of yes/no
  • 53. PAGE 53 KAREO | @GoKareo; #KareoTip Agenda:  Review of key definitions and concepts of the EHR Incentive Program  Adopt: Experiences learned from MU1 and MU2 EHR users  Attest: Issues to address during and after yearly attestations  Audit: Experiences to date  Quality opportunities beyond MU
  • 54. PAGE 54 KAREO | @GoKareo; #KareoTip Beyond Bean Counting: Workflow  Workflow you discussed pre-implementation  Workflow you had in place at go-live  Workflow you had in place before interfaces such as  Digital Fax machines  HIEs with your hospitals and state registries  Exchange (point-to-point or HIE) with your labs  Transfer of care (HIEs or same-EHR-community)  Workflow you have with equipment changes  Nothing in exam rooms  Nothing in MAs hands to all MAs carrying mobile devices  PCs in all rooms  Portable devices wherever you left it last
  • 55. PAGE 55 KAREO | @GoKareo; #KareoTip Workflow CHANGES, all the time. Make the best use of your talent and your tools at the time.
  • 56. PAGE 56 KAREO | @GoKareo; #KareoTip Beyond Bean Counting: Physical Changes  Ergonomic Issues  Mouse/stylus/fingers/keyboards  Counter space/height  Lab space/height for MAs/RNs, etc.  Visual challenges for user, patient  Physical challenges (carpal tunnel, Parkinsons, etc.)  Equipment locations – label printers, fax machines, prescription paper, prescription printers, digital equipment, counter space  Job descriptions: software will change who and where some tasks are completed.
  • 57. PAGE 57 KAREO | @GoKareo; #KareoTip Beyond Bean Counting: Documentation Quality Opportunities  Needs a champion  Many encounters stand alone, but the story over time can highlight bad habits, poor readability, missing info.  Patients, under Meaningful Use, are permitted to read every note and will be able to VDT your note.  What is displayed on your screen is often different than the printed or download version.  Printed documentation is easiest for this peer review task.  Peer review is not discoverable, so be clear and frank. (Check your state’s definitions)
  • 58. PAGE 58 KAREO | @GoKareo; #KareoTip Read a good non-fiction book lately?
  • 59. PAGE 59 KAREO | @GoKareo; #KareoTip Peer Review Examples  “Same Procedure” Stories: Patients with a 58100 biopsy belonging to each provider  “Same Disease” Stories: Patients, all with a diagnosis of hypertension seen by each provider  Abbreviations to ‘anonymize’ the records  MD = any provider, MD, NP, CMW, etc. No provider name, only MD1, MD2, MD3, MD4  MA = any clinical staff, MA, RN  Visit = any documented ‘event’ – chart note, result, message, etc.  No PHI, only patient A, B, C or D
  • 60. PAGE 60 KAREO | @GoKareo; #KareoTip The Process  Reviewers: providers, office, clinical and billing managers  At your leisure, read each Patient/MD story  When all have reviewed the Patient/MD stories, discuss:  Quality for billing  Readability  Best template  Should templates be edited  Workflow or policies need to be changed  Schedule another peer review discussion in 6 months  Consider a different disease or procedure for review  Did the discussions during the first peer review become habit?  Workflow or policies need to be changed, again.  Most importantly, does the story reflect facts?
  • 61. PAGE 61 KAREO | @GoKareo; #KareoTip Ever surprised how much (or how little) water comes out of a garden hose?
  • 62. PAGE 62 KAREO | @GoKareo; #KareoTip Another Review Using “Electronic” Views  What does a ‘screen’ version in the EHR look like?  What does this look like when viewed on the portal?  You’ll need the cooperation of a portal-enabled patient  What does this look like when received by another EP  You’ll need the cooperation of outside physicians  You may send this through an HIE or through DIRECT  You might send this to hospital admissions or L&D  Changes needed?  Accurate, complete, readable?
  • 63. PAGE 63 KAREO | @GoKareo; #KareoTip Roadside Assistance for MU!  Acute Anxiety Attack? Yes, to Anxiety!  Advanced Amphibious Assault? Yes, some days feel like an assault!  Amateur Astronomers Association? Yes, there are definitely “way-off” stars involved.  You’ll be on your way to: –Adopt –Attest –Audit We’re all reading the MU “user manual” as we go…
  • 64. PAGE 64 KAREO | @GoKareo; #KareoTip Our Schedule for Today… 1 Introduction & Welcome Barbara 2 AAA for MU: Roadside Assistance for the EHR Incentive Program 3 Discover Kareo’s Role 4 Answer Questions
  • 65. PAGE 65 KAREO | @GoKareo; #KareoTip Discover Kareo’s Role Cloud-based Insurance & Patient Billing Scheduling & Practice Management Electronic Health Records Medical Billing Services Education, Training, & Support Ranked #1 by Black Book 2 Years 25,000 Providers Nationwide
  • 66. PAGE 66 KAREO | @GoKareo; #KareoTip Discover Kareo’s Role • Kareo EHR • 2014 Edition certified
  • 67. PAGE 67 KAREO | @GoKareo; #KareoTip Discover Kareo’s Role • Kareo EHR • 2014 Edition certified • MU Dashboard
  • 68. PAGE 68 KAREO | @GoKareo; #KareoTip Discover Kareo’s Role • Kareo EHR • 2014 Edition certified • MU Dashboard • Support & Education • MU Expert Service
  • 69. PAGE 69 KAREO | @GoKareo; #KareoTip Kareo Marketplace • Kareo Partners • Certified Specialty EHR partners
  • 70. PAGE 70 KAREO | @GoKareo; #KareoTip Discover Kareo’s Role
  • 71. PAGE 71 KAREO | @GoKareo; #KareoTip Our Schedule for Today… 1 Introduction & Welcome Barbara 2 AAA for MU: Roadside Assistance for the EHR Incentive Program 3 Discover Kareo’s Role 4 Answer Questions
  • 72. PAGE 72 KAREO | @GoKareo; #KareoTip

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