Ah, the life of a hospital CIO. Sometimes everything just falls into place. It doesn’t matter if you work for a 40 bed rural Critical Access Hospital (CAH) or a 700 bed critical care center in an urban center, the satisfaction can be the same. All the details of your CMS EHR incentive attestation were properly vetted, aggregated and attested. The Security Risk Assessment was blessed by the Gods on Mount HIPAA. The EHR incentives came in right on cue for 2012 and 2013 and all that is left is to keep the roadmap for Stage 2 meaningful use (MU) in place for 2014. Life is looking pretty good. Then it happens, out of the blue, right out of your blind spot.
You were deep in the planning of the family summer vacation. Will it be the Turks and Caicos again this year or are the kids old enough to appreciate Italy? Maybe splurge and go for that charter cruise to the Virgin Islands. You are lost in the reverie of palm trees and the promise of not having to wear a watch for a week. Then it hits like a lighting strike out of a clear blue sky.
It comes via email. A letter from CMS that states there seems to be a little problem with a previously received incentive payment. There needs to be an adjustment to the EHR incentive already received. Final calculations on the cost report show an overpayment was made and you have 30 days to refund that amount, which can run very easily into 6 figures. I have seen a few of these letters and without exception it is unexpected.
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The calculations for CMS EHR incentives for EHs and CAHs can be quite complex. In fact they are different from each other. The incentives for CAHs incorporate such variables as “the reasonable costs for the purchase of a certified EHR system”. There is an entire industry of consultants who are available to help interpret and stretch the definition of that phrase. The incentives for EHs also have a few twists and turns. However, there is one thing they have in common. In both cases the MU attestation leads to a preliminary or interim incentive payment. Words like “preliminary” and “interim” can cause the heart to skip a beat or two. Good thing you work for a hospital.
Here is what it means, plain and simple. The preliminary payment, that one that made everybody smile, was based on the most recently filed 12 month cost report. The final payment calculation is based on a later 12 month cost report. We’ll skip the details for now but you get the picture. The EHR HITECH Incentive Payment Center might possibly be contacting you to discuss the overpayment with a polite request to refund the money. Now I haven’t talked to any CIOs that have received notice that there was an underpayment and they will be receiving an additional payment. If that has happened to you, please let me know, as soon as you come back from that charter cruise to the Virgin Islands. For the rest of you, keep an eye on the inbox.
If you are a hospital with a concern over having your EHR incentive payment audited or looking to avoid or mitigate an audit, please contact me at: [email protected].
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Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. As one hospital CEO stated, “we were notified by CMS that the adverse audit decision was being overturned and we did not have to return the 2011 EHR Incentive Payment. I would recommend the services of Mr. Tate and EMR Advocate in the event your facility is notified that it will be subject to a Meaningful Use audit or your facility is audited, or you have an adverse outcome and need to file an appeal." He blogs at Meaningful Use Audits. If you are a hospital with a question about the MU audit and appeal process, email him at: [email protected]
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