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Washington Debrief: Multiyear Meaningful Use Audits Underway

April 6, 2015
by Leslie Krigstein, Interim Vice President of Public Policy
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Leslie Krigstein, Interim Vice President of Public Policy

Washington Debrief: Multiyear Meaningful Use Audits Underway

Key Takeaway: The Office of the Inspector General (OIG) within the Department of Health and Human Services (HHS) confirmed last week that multiyear audits of physician compliance with the meaningful use (MU) program are underway nationwide.

Why It Matters: Healthcare IT executives should have well-established processes to ensure documentation supports their MU attestations. While only a small fraction of providers have failed previous MU audits, Stage 2 requirements will likely be the focus of new audits and the program’s increased complexity from Stage 1 could introduce new risks of failure.

Last week, OIG officials confirmed that multiyear audits of randomly selected physicians are in progress. The audits probe physicians’ reports of attestation to meaningful use going back to 2011. Most audits are aimed at determining whether Medicare and Medicaid incentive payments were appropriately claimed relative to program requirements and to assess CMS’ actions to remedy erroneous payments.

OIG confirmed plans to investigate whether EHRs, particularly those using cloud-based technology, are adequately protecting electronic health information.

Two of the OIG Medicaid EHR incentive completed audits and show mixed results. In Florida, an audit of meaningful use shows payments to 42 Florida hospitals were properly made. While an audit of 19 Massachusetts hospitals found the state overpaid 13 of them a total of $2.7 million for Medicaid EHR attestations, and underpaid six hospitals a total of about $560,000.

Joint Commission Warns Health IT Poses Additional Risks in Complex Healthcare Environment

Key Takeaway: Last week, the Joint Commission published an alert examining the contributing factors to health IT-related adverse events and offered solutions to mitigate provider risk.

Why It Matters: Healthcare IT executives should see the actions of the Joint Commission as a signal that quality and safety experts are growing more concerned over the potential safety implications of a connected healthcare system – good and bad. The ONC is expected to reveal plans regarding a proposed Health IT Safety Center in coming months; it is likely that this and additional information will serve as underpinnings for future policymaking.

The so-called Sentinel Event Alert serves as an update to an alert issued in 2008 concerning the safe implementation of health IT. The Joint Commission alert examined ways to improve the culture of safety, health workers’ processes and general leadership issues.

The alert cites an expect growth in health IT-related unless risk-reducing measures are put into place as EHRs and health IT products are introduced into patient care. The Joint Commission said that EHR systems must be well-designed and appropriately used in order to improve outcomes through their ability to improve data access, provide clinical decision support and to facilitate communication

Specific recommendations from the alert included:

  • Implementing comprehensive systematic analysis of all adverse events to determine whether they were the result of health IT issues; and
  • Limiting the number of patient records that can be displayed on the same screen at once.

CHIME and AMDIS Submit Joint Comments to ONC Interoperability Roadmap

Key Takeaway: The joint response to ONC’s Nationwide Interoperability Roadmap submitted by CHIME and AMDIS applauded the administration’s focus on clear, enforceable standards while calling for more work on patient identification.

Why It Matters: The ONC’s Roadmap will likely guide much of the Office’s policy agenda over the next three years. Healthcare IT executives should view the Roadmap and its successive versions as a blueprint for how federal officials will reorient policies beyond Meaningful Use.

In late January, ONC released a pair of documents detailing how the government hopes to address the multi-faceted issue of interoperability by publishing the Nationwide Interoperability Roadmap and the 2015 Interoperability Standards Advisory. The documents were released in part due to criticism received from Congress and healthcare providers that Meaningful Use, EHR Certification and other programs have failed to deliver systems that demonstrate functional interoperability.  

ONC released the Connecting Health and Care for the Nation: A Shared Nationwide Interoperability Roadmap Draft Version 1.0, proposing critical actions for both public and private stakeholders that will advance our nation towards an interoperable health IT ecosystem, advance research and ultimately achieve a learning health. ONC's Interoperability Roadmap will be used to guide multiple HHS programs and address congressional criticism over the issue of interoperability.

CHIME and AMDIS applauded ONC for creating heightened visibility toward building an interoperable health IT environment through clear, enforceable standards. The organizations’ formal comments cite concerns over the development of tools based on a moving target of immature and inconsistently implemented standards.

The response called on ONC to pursue interoperability in the service of high quality, safe patient care. Specifically, the organizations highlighted patient identification as a pivotal component in the development of an interoperable Learning Health System. A national approach to patient identification is prerequisite for interoperability and the lack of a standard patient identifier only serves to aggravate our industry’s technical challenges.  

Along with the Interoperability Roadmap, ONC released a document meant to identify, assess, and determine the "best available interoperability standards and implementation specifications for industry use toward specific health care purposes." The Advisory identifies specific standards and references implementation guidelines across four areas of standards, including content, vocabulary, transport and services. The Standards Advisory is hoped to be updated annually to reflect industry adoption of key clinical standards. Comments are due on the Standards Advisory on May 1, 2015.

CHIME Workgroups for MU Stage 3 and Health IT Certification Rules

Following release of two rules by CMS and ONC, CHIME is establishing two corresponding workgroups. The MU S3 Workgroup will focus on the CMS rule, including proposed measures / objectives and other policy provisions. The HIT Certification Workgroup will focus on ONC's proposed rule, including plans to broaden the availability to other kinds of health IT, certification criteria for Stage 3 and other provisions. Members interested in joining the MU S3 Workgroup should click here. Those interested in joining the HIT Certification Workgroup should click here.

Edited by Gabriel Perna for style purposes

 

 


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