ORLANDO – Expect a more rigorous process of certification for Stage 2 of meaningful use and be prepared for audits that will withhold incentive payments until all issues are resolved, federal officials advised.
This year is the first that physicians can work to meet the requirements for Stage 2 of meaningful use. Stage 1 was about data capture, but Stage 2 is about sharing information across care settings and between patients and providers, Robert Anthony, deputy director of the Health IT Initiatives Group at the Centers for Medicare and Medicaid Services’ Office of E-Health Standards and Services, said at the annual meeting of the Healthcare Information and Management Systems Society.
Among the core requirements for Stage 2 are establishing a patient portal and ensuring and using secure messaging between patients and providers. Physicians must be able to link to imaging results, report to a registry, and record electronic progress notes.
Alicia Ault/Frontline Medical News
Robert Anthony
Mr. Anthony said that CMS purposely set what he called a "low bar" for patient engagement in Stage 2. To demonstrate meaningful use, 5% of patients must use the practice’s patient portal and 5% must participate in secure messaging beyond appointment booking, he said.
Even so, meeting that target might not be easy. Mr. Anthony said that he had heard from some physicians that they are sitting down with patients at the end of a visit and walking them through use of the portal or the messaging process. Those encounters, he added, can be counted toward the target.
Requirements for documenting care transitions are stricter as well, Mr. Anthony said.
"In Stage 1, ‘transitions of care’ was a menu objective, and virtually none of you selected transitions of care," he said. "We know why everybody didn’t select it – because it’s a difficult objective to achieve."
Care transitions, though, are "the Holy Grail" for showing that systems and clinicians can talk to each other, so the measure was moved into the core objectives for stage 2, he said.
Under Stage 1, physicians could send a summary of care to the next provider by any method, as long as it arrived, said Mr. Anthony. Under Stage 2, summaries must be electronically transmitted 10% or more of the time. At least some have to be sent to clinicians using a different electronic health record system.
Finally, CMS will be performing more audits under Stage 2. The agency must be accountable for the $21 billion spent on incentive payments so far, he said. In stage 1, the audits for Medicare were primarily post payment. Now, payments will be withheld until the audits are resolved. Some 5%-10% of physicians will be subject to an audit. They will be chosen at random or through risk profiling.
And, "no, we’re not going to talk about what raises a red flag, because that’s the point of an oversight program," he added.
So far, documentation has been the primary deficiency found through the audit process, Mr. Anthony said.
"I am shocked by the number of people who do not retain any documentation related to their attestation figures," he said. Physicians need to document the numerators and denominators they use for attestation and then keep that documentation for 6 years.
There are no consultants or companies that have any special knowledge about how to avoid audits or resolve an audit more quickly. They also don’t know anything special about the appeals process. "The process is the same for everybody and is transparent and public for everybody," he said.
"Anybody who is telling you separately that they have some kind of inside line to CMS is drumming up business and nothing more," Mr. Anthony said.
He also said that there is no secret process to getting an appeal. The agency spells out what it is looking for in the appeals documentation available on the CMS ICD-10 website. There’s also a sample audit letter from the CMS contractor, Figliozzi and Co.
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