You may recall several of our articles have discussed important Meaningful Use steps your organization should be taking to ensure compliance with CMS requirements. The following list will discuss 5 of the most important Meaningful Use facts and tips we think you and your organization should be aware of.
1. The Stages of Meaningful Use
Not to be confused with the 5 Stages of Grief although we could argue that Meaningful Use has some similar characteristics and may cause some of us to experience feelings of denial, anger, bargaining, depression, and acceptance.
Instead, there are 3 Stages of Meaningful Use:
- Stage 1 Meaningful Use the "data capturing and sharing" objective;
- Stage 2 Meaningful Use addresses the "advance clinical processes" objective; and
- Stage 3 Meaningful Use aka the "improved outcomes" objective.
During any of these stages we may experience the "grief cycle"; however, the next 3 facts about Meaningful Use are also tips to help you deal with the 5th fact Meaningful Use Audits Happen.
2. Security Risk Analysis
A security risk analysis is important for HIPAA and meaningful use requirements. Under the HIPAA Security Rule, your organization must:
"Conduct an accurate and thorough assessment of the potential risk and vulnerabilities to the confidentiality, integrity, and availability of electronic protected health information held by the organization."
For each stage of Meaningful Use, this HIPAA requirement is reinforced. Groups are required to: conduct a SRA when certified EHR technology is adopted in the first reporting year; complete the SRA process in subsequent reporting years; and also perform the SRA when changes or updates occur. We can't stress the importance of a SRA enough.
3. Medical Assistant Credentialing
In both Stage 1 and Stage 2 of Meaningful Use, regardless of what stage of meaningful use the provider is attesting to, medical assistants are required to be credentialed. The same is true for the proposed Stage 3 Meaningful Use rule. Orders should be entered by a licensed healthcare professional or "credentialed medical assistant" to meet the requirements of each stage of Meaningful Use. Because there is a great deal of focus being spent on a national standard for credentialing of medical assistants we have developed a credentialing course for any non-certified medical assistants, which meets the meaningful use criteria and will allow your non-certified MAs to continue performing that CPOE function into your CEHRT.
4. Documentation is critical
It is critical for you to ensure you have access to all necessary documentation, including your SRA, copies of Medical Assistant Credentials, a copy of the EHR agreement with your technology vendor and a copy of the ONC certification, and any other documentation that supports each meaningful use item to which you attested in that reporting period. For example, Figliozzi & Co. has requested documentation such as screenshots from the EHR system which documents a test submission of syndromic surveillance data to a public health agency OR a letter/e-mail from the public health agency confirming their receipt of electronically submitted syndromic surveillance data.
5. Meaningful Use Audits Happen
Last but not least, meaningful use audits happen.
Imagine you are going through the mail and you notice you receive a letter from CMS. More than likely, your audit will begin with a letter from Figliozzi & Co., a contractor who is performing most of the audits for CMS and will be titled "HITECH EHR Meaningful Use Prepay Audit Engagement Letter & Information Request." After reading the letter the grief cycle may set in starting with denial, but quickly moving to anger not only have you been stressed out ensuring you are meeting Meaningful Use requirements, but now you must prove you are.
CMS and the Office of Inspector General (OIG) have taken steps to audit how providers are meeting meaningful use requirements. Approximately 5 to 10 percent of all meaningful use participants are being audited; this includes pre-payment and post-payment audits.
Being prepared for a meaningful audit requires an organization to maintain good documentation that can easily be provided to an auditor upon request. As mentioned above, it is critical to ensure you have access to all necessary documentation; even then, you may be asked to provide additional documentation or other supporting information as part of the prepayment or post payment process. But don't feel discouraged, we are here to help if you have any questions.
If you have any questions about any of these Meaningful Use Facts or Tips, or if you have any other compliance questions, please feel free to comment below or send us an email at[email protected] or reach us by phone toll-free at 855-427-0427.