Meaningful Use in the Rear View Mirror
The rear view mirror. Now that’s one handy tool. Helps us keep an eye on things that might be gaining on us. Almost as good as having eyes in the back of our heads. Things can creep up on us and before we know it what we have may have forgotten is demanding our attention.
In the past week I have been contacted by four Eligible Professionals (EP) who have been notified they were being audited by Medicare for their CMS EHR Incentives. In all cases the audits were based on 2011 meaningful use (MU) attestations. These could be anomalies, and it is always risky to draw conclusions, but it is obvious to me that the very first year of CMS EHR incentives is an active focus of audits.
In the early years of the MU program, way back in 2011 and 2012 during the Paleozoic period, there was an abundance of confusion in the ether. The fog of misinformation ruled the days. What constituted “one test” of an immunization submission? What was a Security Risk Analysis? If an exclusion could be taken would it be counted as meeting a Menu Measure? There were hundreds and hundreds of these questions. I should know. I got asked them. Well, by the time we made it to 2013 and 2014 the dust had begun to settle. CMS had provided clarifying FAQs and produced tip sheets to guide us along the way.
With each passing year the quality of underlying attestation documentation has continued to improve. MU knowledge has seeped deep into the bones of providers and consultants and those “knowledge gaps” have shrunk in size and number.
The problem is those early MU attestations. They can come back and haunt an EP or EH as those knowledge gaps have never been corrected. In addition, the largest incentives were in the early years, so that brings a doubly jeopardy. The highest risk is with the highest incentives which were shakiest in terms of documentation. . What can one do? Review the documentation in those early attestations, make corrections if possible, and don’t forget to glance at the rear view mirror from time to time.