CMS EHR Incentive Audits: Focus on Critical Access Hospitals (CAHs)
I have a special place in my heart for Critical Access Hospitals (CAHs). Their presence in the healthcare spectrum helps fill the gap in rural medical care. Their future is integral to the well-established national health policy. All 1300+ CAHs in the US play a significant part in continuity of care.
The special nature of the CAHs has made their participation in CMS EHR incentive programs both a blessing and a curse. The cost of purchasing, implementing, and maintaining an EHR in a 25 bed CAH can easily be outside their budget. However, by achieving meaningful use (MU), the CAH could quickly recoup the expense in the initial year by receiving an incentive over $1,000,000 just from Medicare. Sounds pretty good to me. The hospital can effectively transition to an electronic health record at no cost. Pretty good deal also for the vendors who suddenly had many more customers with checkbooks.
CAHs are at a disadvantage to Eligible Hospitals (EH) when it comes to the administration of the CMS EHR Incentive programs. Due to the inherent nature and size of CAHs, staff members often wear multiple hats. I have seen situations where a CAH’s MU attestation responsibility fell on the Director of Nursing. Sometimes the IT department performs it. A large hospital would have a dedicated compliance department that would assume the task of understanding all the nuances of MU strategy, attestation, and related documentation.
I think you can see where I am going here. CAHs are a distinct disadvantage in the administration of the MU incentives process. I hesitate to tell you how many of these smaller hospitals have contacted me during their audits. Sometimes it is impossible to determine who performed the attestation and the basis for their decisions. In some cases it is obvious that information was either totally made up or else there was a complete misunderstanding of the process. Many CAHs have no idea of the validity of their 2011, 2012, or 2013 attestations. An audit is a hard way to discover the truth. I would suggest a proactive path by taking a good look under the covers of those prior attestations. Perform your own audit. If there is a ticking time bomb it is better to know sooner rather than later. There is process to mitigate an erroneous attestation but as is many things, time is the enemy.