Make Meaningful Use Work For You: Choosing a Program, Documenting and Auditing

While attaining Meaningful Use monies isn’t easy per se, you at least know you’ll justify some of your implementation costs. The Medicare and Medicaid Incentive Programs seem pretty clear cut – you meet the CMS-ONC requirements, they cut you a check.

Well, sort of, because it’s not just about implementing an EHR, but also proving you have the capability to use it meaningfully. CMS may conduct audits to ensure you both attain and are maintaining compliance, which means you should be prepared past the Incentive Program’s 90 day period. This can all get a bit overwhelming. Here are the steps to getting paid – weeded and simplified.

The Basics: Medicare vs. Medicaid
Physicians choose between the Medicaid and Medicare Incentive Programs for implementing an EHR.

Eligible practices that can claim at least 30% of Medicaid patients that wish to attest to the Medicaid program have it a little easier – $21,250 for adoption, implementation, or upgrading to EHR. The program’s latest time to earn the maximum amount is 2016, there’s a concurrent ePrescribing bonus element and total payments amount to $63,750 over 6 years.

To participate under Medicare, eligible professionals attest to the Meaningful Use Stages for $44,000 over 5 years if they start by 2012. The Medicare program also requires that eligible professionals demonstrate attestation during a 90-day period and are subject to random audits later.

So why even choose the Medicare Program? For one, the Medicaid program is run by your state Medicaid agency, which may prove to be more volatile, or you may reside in one of seven states that aren’t yet eligible. The Medicare EHR Incentive Program, on the other hand, is run by CMS.

Also, some providers may not qualify for the Medicaid program, which makes the Medicare program the only viable option. And lastly, some professionals aren’t eligible for the Medicaid program at all, including doctors of dental medicine, podiatry, optometry or osteopathy.

For more help on choosing between the two programs, check out CMS’s EHR Decision Tool.

Medicare EPs: Time-Based Requirements
First thing’s first – make sure you’re implementing an ONCHIT-approved EHR, via one of many testing bodies, i.e., Drummond Group or the Certification Commission for Health Information Technology (CCHIT). This is the first step to guaranteeing you get paid.

These EHRs must make it easy to follow the electronic specifications developed by CMS, which include data elements, logic, and definitions for each clinical quality measure (CQM) Meaningful Use has you meet. This facilitates the 90-day reporting period during the first payment year.

For some help or tips on how to attest to the Medicare program, take a look at this article.

Don’t Let Audits Get In Your Way
To get paid, providers must ensure they have a National Provider Number (NPI) and a Provider Enrollment, Chain and Ownership (PECOS) enrollment record. Not only is this required as you begin attesting, but they’ll come in handy if you’re audited after attestation.

What the CMS expects to gain from conducting audits after the initial reporting period compliance period is the security that providers are maintaining Meaningful Use compliance. And you need to be prepared.

As a provider attesting to receive an incentive payment, ensure you retain all relevant supporting documentation, in either paper or electronic format, for six years.

Information regarding CQMs and payment calculations performed by hospitals comprise additional documentation up for auditing, so providers cannot stop following documentation retention processes.

Lastly, it was announced in July that Figliozzi & Company had begun work as CMS’s auditor for the Incentive Programs. Audited providers will have two weeks from the receipt of a letter to reply to Figliozzi & Company’s requests.

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