Tuesday, July 9, 2013

Incentive Payments a Dangerous Double Edged Sword


The letter the hospital received said it all, “Based on our desk review of the supporting documentation furnished by the facility, we have determined that Hospital X has not met the meaningful use criteria………….Since your facility did not meet the meaningful use criteria, the EHR 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.

A significant number of hospitals and providers will receive a letter such as this. which reminds me of a song “Money for Nothing” by Dire Straits .

The Appeal of a Failed EHR Incentive Audit.

If that doesn’t get your attention, nothing else will. I wouldn’t want to be the one that received the email and have to be the one to show it to the hospital CEO or Board. I would imagine the CFO also would not be too pleased. It sounds so final, “did not meet the meaningful use criteria” and “will receive a demand for  your total Medicare EHR incentive payment shortly”. I guess that is why it is call Final Determination. It sounds like a death sentence. But it doesn’t have to be.

A whole new  industry of consultant experts will now descend upon unsuspecting hospitals and providers.

As consultant Jim Tate (EMR Advocate)  goes on to say,

“I was contacted by the hospital the week after they received notification they had failed their EHR incentive audit and to expect a demand letter for a seven figure recoupment. They only failed one meaningful use measure, and it wasn’t the infamous Security Risk Analysis. If I had been on board earlier I could have perhaps helped with documentation and clarification that would have met the expectations of the auditor. It is hard to go back and reconstruct what happened during the 2011 attestation. Staff changes and memory fades. By the time I knew anything the audit was failed and they were behind the eight ball. Not a good place to be.

We were told we were the first hospital that took a failed audit decision to the appeal level. That’s right, we were #001. We worked through the appeal process by providing additional clarifying documentation and participating in a number of conference calls. I felt we received a fair and transparent hearing. Last week the hospital received an email stating, “….we are reversing the adverse audit determination”. Now that is one email I bet everyone was glad to share. Thank their lucky stars. I hope you have a few of those lucky stars in your sky if you need them.”

Lesson #1   Bring in the consultant before you submit the original data. The investment will be much less than afterward financially, to say nothing about the angst and discord for hospital administration.

HHS seems shortsighted in that this is only the first or second round of attestation for meaningful use. There are sure to be problems with the process.

It seems unjust that providers and hospitals should have to pay for the continuing recalcitrance of HHS to plan a workable schedule for implementing their laundry list of things which must be done.

Our faith and trust are wearing very thin….not just in health care. Here is another example of incompetent management style……along with the necessity of delaying the employer mandate.  The fabric of Obama Care is unraveling quickly.


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