How to Reduce EHR Incentive Audit Anxiety

Sarah Tupper, REACH HIT Consultant
Edited by Patti Kritzberger, REACH HIT Consultant

Picture this: Less than 24 hours remain until you are ready to depart on a much-needed and well-deserved vacation from your organizational responsibilities around meaningful use, when KAPOW, you get an email from the CMS EHR MU Incentive Program or Figliozzi & Co. notifying you that your CAH/EH or EP(s) are the subject of an audit!  How do you respond? With: 1) Cold sweat and racing heart beat?; or, 2) Calmly click through your well-organized audit efiles, upload the requested documents to the Figliozzi portal and, within hours, you are relaxing on the beach with your favorite cool beverage in-hand?

Let REACH help you achieve the latter scenario. We have assisted more than 40 organizations with audit guidance and/or audit preparation site visits to help ease anxiety around audits.

Today, let’s focus on the first step, an organized filing system.

For CAH/EH’s, consider the following efile structure:

EPs will follow a similar structure, but remember you will be audited on individual EPs, so you will want individual folders for each EP.  Something like the following:

Obviously, organized files are only the first step.  To learn more about how REACH can help, contact your assigned REACH HIT Consultant.  If you are not yet a REACH client, please contact Bill Sonterre at BSONTERRE@stratishealth.org, and…may all of your vacations be audit-worry free!

REACH Develops Data Analytics Portal to Help Clients Understand and Apply Analytics to Data

Ryan Sandefer, Chair & Assistant Professor, The College of St. Scholastica - Department of Health Informatics and Information Management

It is clear that the health care industry must transform to improve care quality and reduce costs. Health information technology (HIT) has the potential for impacting care delivery, and one of the areas that will continue to play a major role in this effort is big data and data analytics. The industry is looking to the massive levels of data being collected through HIT to identify cost savings and quality improvements. I recently read that within a decade the global level of health care data will see a fifty-fold increase, or the equivalent of moving from 10 billion to 500 billion four-drawer file cabinets. While HIT clearly has the capability to collect this data, health care organizations are overall at a loss for how to use this information to drive improvements in clinical outcomes, administrative operations, and financial performance. With the requirements of meaningful use increasing with the progressive stages of the electronic health record (EHR) Incentive Program and the activities of accountable care organizations heating up, health care organizations will be looking to REACH, vendors, professional associations and other stakeholders to help them better understand policy-related requirements for these programs and to understand the tools and resources to help them leverage their data to retrospectively understand their patient populations and clinical performance and predictively identify patients needing some type of intervention.

Based upon findings from a survey that we conducted of REACH clients, organizations do not have the trust in their data, the skilled workforce, or the technology to accomplish the major activities associated with data analytics. In an effort to assist REACH clients on their journey to better understand and apply analytics to their data, REACH has created the Data Analytics Portal. The portal is a comprehensive educational resource for clients to better understand meaningful use and all phases of the data analytics lifecycle, including data acquisition, extraction, aggregation, analysis, and interpretation. This portal provides REACH clients with tools and resources to assist with data analysis projects, including educational presentations, customizable tools, and online resources.

The portal consists of three major content areas—Understand, Collect, and Apply—and each content area has multiple sections. The portal covers all aspects of data analytics, including an introduction to data management, clinical quality measures project management, privacy and security, statistics, data mining, and using open source software.

Identifying areas for quality improvement and cost reduction is the purpose of meaningful use, and REACH is excited to be a part of this movement.

Access the Data Analytics Portal >

REACH Audit Readiness Assessments

Sarah Tupper, MS, RN-BC, LHIT, CPHIMS, REACH HIT Consultant
Edited by: Reid Haase, REACH HIT Consultant

Roughly 7.5 billion dollars of incentives have been paid out to eligible hospitals and providers through the EHR Incentive program. The Office of the Inspector General (OIG) has demanded better oversight of these payments by CMS. CMS has hired a consulting firm (Figliozzi & Co.) to conduct these pre- and post-payment audits of about 5-10% of Meaningful Use program participants.

In late May, based on requests and questions received from clients, REACH decided to begin offering FREE Audit Readiness Assessments to clients with an active Service Level Agreement. More details are available in this flier.

Audit Readiness Assessments can be scheduled in coordination with your REACH HIT Consultant. An on-site visit is scheduled after a prep call. During the site visit, we provide anticipatory guidance to clients for things like:

• How they might hear that they are being audited
• How to organize their files to maintain their audit documentation
• What documents to keep and how long to keep them
• Screen shots to take
• Advice that we have picked up from our clients who have already been audited.

So far, we have received 21 requests for the service at various client sites. 17 of the 21 sites have received or will receive a REACH Audit Readiness Assessment site visit.

We hope to be able to provide the service to all REACH clients who qualify and for which the service is appropriate. I always tell clients that these site visits are fun! It’s fascinating to hear and see the ways in which organizations have come together and, in some cases, gotten quite creative with workflows that support Meaningful Use. We learn together, and hopefully help to reduce the stress clients might feel should they receive audit notification. If you are interested in learning more about the audit process, or would like to schedule one, please contact me: stupper@stratishealth.org (for MN clients) or Patti Kritzberger at: pkritzberger@stratishealth.org (for ND).

National Rural Health Resource Center Releases HIE Toolkit

Joe Wivoda, National Rural Health Resource Center, Chief Information Officer and REACH HIT Consultant

One of the groups that the National Rural Health Resource Center (The Center) provides technical support to are Rural HIT Networks. The Center identified early on that many of the networks were either in the process of selecting a health information exchange (HIE), participating in an HIE, or needed to understand HIE. HIE (as a noun) is a rapidly evolving technology that all health care providers will need to understand, particularly in the context of meaningful use. The Center looked for tools that would assist networks in being involved in an HIE but were unable to find many good tools. Therefore, we partnered with HIELix, a company that consults with HIEs across the country, to develop an HIE toolkit that would be appropriate for the grantees that we support.

This toolkit is exciting because it fills a void that has not bee addressed when most folks talk about HIE (as a verb or noun!). For example, we had a number of questions about policies that were important to have in place when forming an HIE, so we put together a "Policy Matrix" that summarizes the necessary policies and provides links to samples that are available. In addition, there is a Privacy and Security Overview and Resource List that provides a "deep dive" into the issues of privacy and security when participating in an HIE.

Most of us feel comfortable that HIE can have a significant impact on patient care and communication to other providers, but we often need to justify the return on investment as well. The ROI Calculator uses referable studies to provide an estimate of the potential savings when an HIE is fully utilized. The feedback we have heard thus far has been very positive regarding this tool, and I encourage everyone who is thinking about participating in an HIE to go through this spreadsheet. If you are implementing an HIE, we are putting together a pricing model as well, but it is not ready for "prime time". Let us know if you have a need for this, or some ideas!

Other tools that are part of the toolkit are the HIE Direct Guide, which is designed to assist hospitals and providers in understanding and implementing Direct, and the First Considerations document, which discusses first steps in forming or joining an HIE. These are great resources for anyone who needs to understand Direct or is joining an HIE. They are written with as little "techno speak" as possible!

Take a look at these resources, give us feedback, ask us questions, and help us improve them! We are excited about these tools and hope they will help hospitals, clinics, long-term care, homecare, and other providers. With meaningful use Stage 2 starting in just a few weeks, HIE participation will increase and we need to move quickly. Besides Stage 2, better communication between providers is so important in patient safety and quality of care that we need to use HIE (noun) to improve our processes for HIE (verb).

Oh, and sorry for the grammar confusion!

Creative Solutions to Expand Rural Health IT Funding

Many health care facilities, particularly rural hospitals, continue to struggle with how to access funding to support the implementation of electronic health records. Bill Menner, the Iowa State Director of Rural
Development with the USDA, and Leila Samy, the Rural Health IT Coordinator for ONC, recently wrote a blog post on how to create funding for critical access and rural hospitals in Iowa. This blog post at HealthIT.gov outlines the unique challenges that the rural hospitals face and some potential 'recipes for success'.

Dr. Kleeberg Goes to Washington to Discuss the Consequences of a “Reboot”

Paul Kleeberg, MD, REACH Clinical Director for Minnesota and North Dakota

Last April six senators led by Sen Thune (R-SD) sent a letter to Secretary Sebelius expressing concern that the money being spent on the EHR incentive program was not money well spent.  They detailed these concerns in a white paper called “REBOOT: Re-examining the strategies needed to successfully adopt IT”.

Among their concerns were that the program:

• Lacked a clear path toward interoperability
• Payments were made without evidence of meaningful use
• EHRs were increasing the ordering of unnecessary tests and increased billing
• Provided inadequate safeguards to protect against fraud and abuse
• Does not require providers to demonstrate their technology is secure
• Does not assure sustainability with penalties hitting providers, especially small providers
• Created a patchwork of overlapping reporting requirements

The white paper was part of a broader effort to solicit feedback from the administration and the provider community about the incentive program.  Some of the info in the white paper is accurate while some was misguided or inaccurate.

Sometime the week of July 1, the HIMSS Government Relations and our Institute for eHealth Policy were asked by lead staff of the “Reboot Group” to convene a series of closed-door bipartisan Senate staff briefings so that they could prepare for what are likely to be at least three upcoming Senate Finance hearings on the status of HITECH. The hearings will start on July 17th with ONC and CMS as witnesses.   The first briefing was scheduled for July 10th.  HIMSS arranged for me as HIMSS Chair-elect and head of the North Dakota-Minnesota Regional Extension Center (REACH) to brief the group along with Elliot Sloane, Ph.D. an expert on data standards and co-chair of the IHE (Integrating the Healthcare Enterprise) International Standards body and Janet Marchibroda, Director of Health Innovation at the Bipartisan Policy Center.  This briefing was attended by 36 Republican and Democratic Senatorial staffers.  The three of us updated them on what the incentive program has been able to accomplish and the data that show the program has clearly driven the adoption of electronic health records.  We also pointed out that the interoperability standards that are required for Stage 2 will include the ability and requirement to exchange patient information across silos of care.  Finally we described how reporting requirements are being harmonized allowing providers to report once and satisfy several programs.

We also highlighted a number of concerns.  One is the growing disparity between the rural and the urban/suburban.  Many of the larger systems that had adopted EHRs before the creation of the incentive program have seen clinical and financial benefits.  Their products have had years to mature and these facilities have had years to compile patient data and redesign their workflows.  These factors have made it easier for them to get the benefits of EHR use and to achieve meaningful use.  For most of the hospitals in rural communities, it is a different story.  Many are only now beginning to use EHRs and many of the products designed for small hospitals are not as mature as those in larger systems.  We also pointed out that small hospitals do not have the IT staff of a large system and that their geographic isolation creates a barrier for them to find the staff and resources to necessary to implement and optimize the use of an electronic health record.  We urged that they pay attention to the needs of these communities in order to not further deepen the digital divide.

We also made it clear that to “reboot” now would derail a program that was clearly headed to the interoperability goals that some of the senators did not believe were in 2014 certified software and Stage 2 requirements.  Meaningful Use requirements come in phases and each release is timed so as to learn from the previous phase while allowing enough time for vendors to enhance their software and time for providers to adopt the software for the next phase.  This “course correction” is built into the current incentive program negating the need of a “reboot.”

Finally, we expressed our concern for the providers who, through no fault of their own, have been unable to implement certified software.  Some hospitals have encountered long waiting periods, and recently, some hospitals have seen their promised upgrade schedules for 2014 certified software be delayed indefinitely by their vendor.  Though they may be able to apply for a hardship exemption so as to avoid the penalties, these facilities will lose out on the incentive designed to assist them in the cost of implementation and will no longer have access to the subsidized technical assistance from a Regional Extension Center.  This issue will also need their continued attention.

In all, it was a great experience and great opportunity for which I am grateful.  Thanks to the HIMSS staff responding so quickly to the request, we were able to make 1/3 of the senate offices aware of the value of the incentive program, why it should continue and, at the same time, make them aware of some of the issues that will need continued attention.

What You Need to Know about the MEIP 12 Month Rolling Qualification Period

Reid Haase, REACH HIT Consultant

As many eligible providers (EPs), eligible hospitals (EHs), and critical access hospitals (CAHs) move into year two of the MN Electronic Health Record (EHR) Incentive Program (MEIP), participants are required to qualify for the program annually, in part, by calculating their minimum patient volume (MPV). The MPV has, to this point, been calculated during a chosen 3-month period within the prior calendar year for EPs or the prior fiscal year for EHs and CAHs. For EPs, the threshold for MEIP qualification is 30% of all encounters (20% for pediatric providers) and 10% for EHs & CAHs. With the release of the Stage 2 rule last August, states were given the latitude to also allow a 12-month 'rolling' period as an option along with the 12 month prior calendar or fiscal year. MN opted for, and was granted, the ability to do the new 12-month 'rolling' period as of January 2013. Note that this change can also be utilized by clinics doing a group EP, rather than individual EP qualification.

Program participants can choose either the 12 month prior calendar or fiscal year or opt for the 12-month 'rolling' period which ends the month prior to the month in which they attest. Example: An EP wishes to attest to his/her second year in October 2013. The chosen MPV 30% period could occur in calendar year 2012 or between October 1st, 2012 and September 31, 2013.  An advantage of this rolling 12-month period could be for EPs that recently joined a practice and would otherwise not have the minimum encounter volume. An EH/CAH example of why this would be beneficial would be for those organizations that might not meet the 10% threshold in the prior fiscal year, but were able to meet or exceed 10% when looking at a rolling 12-month period with more recent encounter data.

MPV references (see the first and second bullets on page 67)

Provider Eligibility: Patient Volume Calculation
90-day period for Medicaid patient volume calculation:

• Under Stage 1 rule, Medicaid patient volume for providers calculated across 90-day period in last calendar year (for EPs) or Federal fiscal year (for hospitals)
• Under Stage 2 rule (applicable to all stages), States also have option to allow providers to calculate Medicaid patient volume across 90-day period in last 12 months preceding provider’s attestation
• Also applies to needy individual patient volume