Drew Memorial Comes Out a Winner in MU Audit Process
As the San Francisco Giants face off against the Kansas City Royals in tonight’s opener of the World Series few would have thought two wild card teams would meet to decide our National past time’s championship. And certainly no one predicted the Royals to be here. The team hasn’t been to the World Series since 1985. 1985! Half the people I meet at HIMSS aren’t even born before then. Yet, against the odds and against predictions, here the Royals are, ready to make late October drama.
Speaking of drama, like the Royals, few would have predicted Drew Memorial Hospital would come out a winner in an MU audit story that made health IT headlines news four weeks ago. After failing an audit for not properly meeting Core Measure 14, a host of news outlet picked up the story, leading with dire predictions that the 49-bed hospital in Monticello, Arkansas would need to repay $900k in Stage 1 EHR inecentives. Meaningful Use Core Measure 14 requires hospitals conduct a Security Risk Analysis in accordance with the requirements under 45 CFR 164.308(a)(1).
Here’s a rundown of the various news stories:
Becker’s Health IT & CIO Review: Drew Memorial Hospital faces loss of $900k in EHR incentives after failing audit
Clinical Innovation + Technolgy: Ark. hospital might have to give back $900K Stage 1 incentive
EHR Intelligence: Meaningful use audit leaves Arkansas hospital owing $900,000
Fierce EMR: Arkansas hospital fails one MU measure, told to repay more than $900K
First, a little bit of back drop. When an Eligible Hospital (EHs) or Eligible Professionals (EPs) receives an audit letter, here’s what generally happens:
- The EP or EH is emailed a letter of audit engagement to the email address provided during registration for the EHR Incentive Program.
- The letter requests supporting documentation for the specific attestation in question.
- CMS audit contractors review the submitted documentation and makes a final determination.
- The final determination is either a favorable one or it’s a very bad day:
- “We performed a desk review on your facility’s meaningful use attestation for the Program Year ____ and Payment Year ____. Based on our desk review of the supporting documentation furnished by the facility, we have determined that Hospital XYZ has met the meaningful use criteria.”
- “We performed a desk review on your facility’s meaningful use attestation for the Program Year ____and Payment Year ____. Based on our desk review of the supporting documentation furnished by the facility, we have determined that Hospital XYZ has not met the meaningful use criteria, for the following reasons: Failed Eligible Hospital Meaningful Use Core Measure X. Since your facility did not meet the meaningful use criteria, the incentive payment will be recouped.You will receive a demand for your total Medicare EHR incentive payment shortly from the EHR HITECH Incentive Payment Center.”
Drew Memorial had a very bad day. Yet, even on the darkest day, there is a silver lining and in this case, it is that CMS gives audited EPs and EHs a process for appealing a failed MU audit. Yesterday, hospital executives received word that their audit appeal was upheld by CMS.
Predicted outcomes and the Royals aside, how did Drew Memorial go from being one strike out away in the bottom of the 9th to a Mr. October moment? (For those of you who are not baseball fans or born after 1985, Mr. October is the famed Reggie Jackson).
I had a chance to speak with the CEO of Drew Memorial Hospital yesterday after he received the good news. Here’s what Scott Barrilleaux had to say.
“I arrived at DMH in May of 2014 and learned in August of 2014 that the audit was heading down a bad path. At that time, we requested several extensions from the audit firm, Figliozzi & Co. My team and I communicated frequently about the audit process and steps were taken to address all issues raised. It wasn’t long, however, before we realized that Core Measure 14 was going to be problematic. Needless to say, we failed the audit because Core Measure 14, according to the auditor, fell outside of the required measures.”
Pursuing an appeal, Mr. Barrilleaux contacted Jim Tate. Full disclosure here: As many of you know, Jim is our own in-house meaningful use expert . He is also the founder of a firm that works with hospitals on MU audits, appeals, and mock audits.
From Mr. Barrilleaux: “After we learned from Figliozzi that we failed the audit, we also learned of Jim Tate and his firm. We contacted Jim and requested information, then contracted his firm to assist us with the appeal. We’re obviously thrilled with the news we received today that the appeal was upheld.”
Go Drew Memorial Hospital. Go Royals.