View
105
Download
1
Embed Size (px)
Citation preview
© 2014 Zetter HealthCare
Auditing PQRS & Meaningful Use To Maintain Compliance
Presented by
David J. Zetter, PHR, CHCC, CPCO, CPC, CPC-H, PCS, FCS, CHBC, CMUP
2014 NAMAS ConferenceAsheville, NC
December 9, 2014
© 2014 Zetter HealthCare
Standard Disclaimer
This material is designed to offer basic information. The information presented is based on the experience, training and interpretation of the author of governmental programs. Although the information has been carefully researched and reviewed for accuracy and completeness at the time of presentation, neither the author, nor NAMAS or DoctorsManagement accept any responsibility or liability with regard to errors, omissions, misuse or misinterpretation.
2
© 2014 Zetter HealthCare
Learning Objectives
Gain better understanding of PQRS Responsibilities
Gain better understanding of Meaningful Use Responsibilities
How to be Proactive How to Prepare and What you will Need for
an Audit Be NOT afraid…
3
© 2014 Zetter HealthCare
PQRS
No alignment between MU and PQRS Need to know PQRS to audit it Beginning in 2015, the program will begin
applying a payment adjustment to eligible professionals who do not satisfactorily report data on quality measures for covered professional services in 2013
2014 is the last year to receive a .5% incentive for reporting
4
© 2014 Zetter HealthCare
PQRS
Eligible Providers Doctor of Medicine Doctor of Osteopathy Doctor of Podiatric
Medicine Doctor of Optometry Doctor of Oral Surgery Doctor of Dental
Medicine Doctor of Chiropractic
5
Eligible Providers Physician Assistant Nurse Practitioner Clinical Nurse Specialist Certified Registered
Nurse Anesthetist Certified Nurse Midwife Clinical Social Worker Clinical Psychologist Registered Dietician
© 2014 Zetter HealthCare
PQRS
Eligible Providers Nutritional Professional Audiologists Physical Therapist Occupational Therapist Qualified Speech – Language Therapist
6
© 2014 Zetter HealthCare
PQRS Eligibilty
7
© 2014 Zetter HealthCare
PQRS Reporting
Medicare Part B FFS or Railroad Medicare Claims-based (2013 and prior) Registry Qualified Electronic Health Record (EHR) or
EHR product Qualified Clinical Data Registry (QCDR) Group Practice Reporting Option (GPRO)
8
© 2014 Zetter HealthCare
PQRS Reporting
Avoiding 2.0% payment adjustment in 2016 Physicians working for more than one
organization need to meet the reporting criteria for each tax identification number (TIN) under which (s)he works during the 2014 PQRS program year to avoid the 2016 PQRS payment adjustment for each TIN.
9
© 2014 Zetter HealthCare
PQRS Reporting
Measures Groups: entry of 20 unique patient charts (11 of which have to be Medicare Part B FFS patients)
Individual Measures Reporting: choose at least 9 individual measures from at least 3 National Quality Strategy (NQS) domains and report at least 50% of the applicable Medicare patient visits
10
© 2014 Zetter HealthCare
PQRS Reporting
Payment Adjustment Avoidance: allows the reporting of at least 3 measures and 50% of eligible patient visits in order to avoid the 2016 -2% payment adjustment – (but not gain the incentive) for 2014 PQRS reporting
GPRO (Group Practice Reporting Option): groups of 2 or more operating under a single TIN and the same reporting requirements as Individual Measures Reporting, but applied to a group practice
11
© 2014 Zetter HealthCare
PQRS Workflow
12
© 2014 Zetter HealthCare
Mock Audits
Record of documentation Measure groups Individual measures Data mine or reports Data entry Proof of submission Live results CMS Feedback Guarantees
13
© 2014 Zetter HealthCare
PQRS Audits
AMA calls to bench PQRS audits Inadequate preparation and response time Conflicting requirements not under physicians’
control Reporting period challenges
PV Modifier is coming…
14
© 2014 Zetter HealthCare
Meaningful Use Audits
Take the money and run? Proof is in the pudding Figliozzi & Company
Electronic letter from CMS address Possible on-site review Demonstration of EHR
15
© 2014 Zetter HealthCare
Meaningful Use Audits
650 & 10,000 4.9 & 21.9 Success! Audits are here to stay
16
© 2014 Zetter HealthCare
Meaningful Use Audits
Checklist Point person MU registration EH’s – final cost report Medicaid volume calculation Proof of ownership Certification ID
17
© 2014 Zetter HealthCare
Meaningful Use Audits
Checklist (cont.) Proof of adoption, implementation or upgrade Allowable costs for purchase of CEHRT Medicare share calculation Attestation submission Other administrative evidence
18
© 2014 Zetter HealthCare
Meaningful Use Audits
When does the process really start? Mock audits Is it too late? Initial review process Additional requests for
information/documentation Secure communications process
19
© 2014 Zetter HealthCare
Meaningful Use Audits
The Keys CMS -> Medicare and dually eligible
Medicaid/Medicare providers States -> Medicaid providers Numerous pre-payment edit checks built into
the Programs' systems Detect inaccuracies in eligibility, reporting, and
payment.
20
© 2014 Zetter HealthCare
Meaningful Use Audits
The Keys Great documentation 6 year retention schedule Reports MUST match exactly
Snapshots vs rolling totals Report must match organization & provider
NPI, Provider or Organization name
21
© 2014 Zetter HealthCare
Meaningful Use Audits
Ex: Stage 2, summary of patient care records for more than 50% of transitions of care or referrals. Denominator is the total number of transitions and referrals that occurred during reporting period, while numerator is actual number of case summaries sent electronically to other facilities or clinicians. The numerator and denominator translate into a percentage the CMS is looking to confirm
22
© 2014 Zetter HealthCare
Meaningful Use Audits
The Keys Yes or No answers Don’t fret, just plan ahead Appeals process (one chance)
23
© 2014 Zetter HealthCare
Meaningful Use Audits
Ex: Requires providers to prove the ability to share clinical data electronically with another care provider that has a different EHR system -- to prove the organization's interoperability capabilities.
24
© 2014 Zetter HealthCare
Meaningful Use Audits
Possible Documentation (preparation) Copies of EHR purchase invoices Licensing agreement List of offices and use of CEHRT
Proof that 50% or more of patient encounters seen using CEHRT
Maintain other charts? Proof that 80% of patients seen in period were
maintained in CEHRT
25
© 2014 Zetter HealthCare
Meaningful Use Audits
Possible Documentation Copies of EHR reports w/ evidence produced for
named EP, EH or CAH Reports with patient lists included in numerators
and denominators Step-by-step screenshots of EHR system with
measures included Copy of security risk analysis for each year being
audited
26
© 2014 Zetter HealthCare
Meaningful Use Audits
Possible Documentation (preparation) Copy of security policies derived from risk
analysis Drug-Drug/Drug-Allergy Interaction Checks and
Clinical Decision Support Electronic exchange of clinical information Proof of any exclusion
27
© 2014 Zetter HealthCare
Meaningful Use Audits
Possible Documentation (preparation) Immunization registries data submission Reportable lab results to public health agencies Syndromic surveillance data submission
28
© 2014 Zetter HealthCare
5 STEPS OF AUDIT SURVIVAL
Resist the PURGE Look back Space constraints
Audit logs & polling data Attestation evidence
Binders vs. PDF
29
© 2014 Zetter HealthCare
5 STEPS OF AUDIT SURVIVAL
Plan ahead Produce the data Space constraints
Audit logs & polling data Attestation evidence
Binders vs. PDF
30
© 2014 Zetter HealthCare
5 STEPS OF AUDIT SURVIVAL
The Unexpected Deep dive into risk assessment
Proof of focus – EHR and modules Audit, report & reaction w/I attestation period
Don’t trip
31
© 2014 Zetter HealthCare
5 STEPS OF AUDIT SURVIVAL
Upgrades? Think about it. Proof of CEHRT the entire time Which reports to use?
Act Fast Quick response to audit request Request an extension Work with the auditor
32
© 2014 Zetter HealthCare
RECAP
Reviewed of PQRS Responsibilities Review of Meaningful Use Responsibilities Ready to be Proactive Preparation & Tools Be NOT afraid…
33
© 2014 Zetter HealthCare 34
For Follow-up QuestionsContact:
David J. Zetter, PHR, CHCC, CPCO, CPC, CPC-H, PCS, FCS, CHBC, CMUP
717.691.7100
Email: [email protected]
Subscribe to our newsletter at www.zetter.com
www.facebook.com/zetterhc
www.twitter.com/djzetter
www.linkedin.com/in/djzetter
Stay on top with what’s going on in healthcare: