Stage 2 Meaningful Use Audits: Focus on Hospitals and Patient Engagement
Some times it is almost too easy to see what lies ahead. They say hindsight is 20/20 but from time to time peering into the future can also be a breeze. A specific challenge coming for Stage 2 Eligible Hospitals (EHs) and Critical Assess Hospitals (CAHs) hides in plain sight in the Core meaningful use (MU) measures. Difficult to achieve, as it is dependent on new technology and workflows, it might be even more difficult to document during an audit.
This Stage 2 requirement seems so simple, and is shorter than a Tweet: “Provide patients the ability to view online, download, and transmit information about a hospital admission.” However, don’t forget this MU measure is Core and very difficult to exclude unless the hospital is way out in the boonies far from the reach of widespread broadband internet access. Fail to meet this MU requirement for Stage 2 and that EHR incentive goes totally away for the year. I would not want to be the bearer of that news to the hospital board or administration. Even if there is a successful attestation on this measure it could be problematic during an audit. Hospitals tend to use technology from various vendors. If you choose a “best of breed” patient portal how hard will it be to track those patient trips to the portal to view their discharge information?
Enough talk. Let’s see what this “patient engagement” portends. There are two parts for our consideration. One is what the hospital must do, the other task is for the patient.
Hospital action required: “More than 50 percent of all unique patients discharged from the inpatient or emergency departments of the eligible hospital or CAH (POS 21 or 23) during the EHR reporting period have their information available online within 36 hours of discharge.” There is no way around this and no short cuts. You have to have a portal and you have to make discharge information available within a limited amount of time.
Patient action required: “More than 5 percent of all unique patients (or their authorized representatives) who are discharged from the inpatient or emergency department (POS 21 or 23) of an eligible hospital or CAH view, download or transmit to a third party their information during the EHR reporting period.”
So we don’t need to dust off our crystal ball to see a curve ball is coming our way. I can already hear the hue and cry that will emerge in 2014 over this issue. As the wizard said in Lochiel’s Warning: “coming events cast their shadows”.
Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. His unique combination of skills has brought successful outcomes to hospitals at risk of having their CMS EHR incentives recouped. He led the first appeal challenge in the nation for a client hospital that had received a negative audit determination. That appeal was decided in favor of the hospital. He has also been successful in leading the effort to reverse a failed appeal, even after the hospital had received notification of the failure with the statement, “This decision is final and not subject to further appeal”. That “final” decision was reversed in less than a week. If you are a hospital with questions or concerns about the meaningful use audit process, contact him at: firstname.lastname@example.org.