Medicare EHR incentive payment oversight lacking, say auditors


Lacking documentation from medical providers that they actually make meaningful use of the electronic health record systems bought with federal subsidies, the Medicare program has left itself vulnerable to the possibility that providers aren't making full use of the systems, says the Health and Human Services Department office of inspector general.

In a report (.pdf) released publicly Nov. 29, auditors note that the Centers for Medicare & Medicaid Services estimates it will pay $6.6 billion through 2016 for Medicare providers to adopt EHRs, on the condition that they fulfill the requirements of "meaningful use" standards. Providers must self-verify their compliance to CMS--but the center doesn't verify the accuracy of those affirmations, auditors say.

Verification is hampered by the fact that no data sources may exist for many of the meaningful use measures, auditors say, and the Office of the National Coordinator for Health Information Technology doesn't require certified EHRs to produce reports on compliance with all meaningful use requirements.

Nonetheless, CMS could select a subset of providers based on risk analyses from whom it could request supporting documentation, auditors say. CMS does plan to conduct postpayment audits to check for meaningful use, but CMS regulations don't provide sufficient detail on what types of documentation providers should keep, auditors also say.

CMS officials told auditors they'll ask for documentations such as screenshots, but even should providers retain all of the types of supporting documentation that CMS wants, they would not be sufficient to verify self-reported meaningful use information for three measurements: drug-drug and drug-allergy interaction checks; one clinical decision support rule; and drug formulary checks.

Those measures "may be particularly vulnerable to noncompliance," auditors say, since they require use of clinical decision support tools," which physicians often view as onerous or unnecessary."

Because screen shots capture just an instant in time, they can't verify that care providers are relying on clinical support tools.

Among auditors recommendations are that ONC start requiring EHRs as a condition of certification to be capable of reporting more extensive meaningful use reports and that CMS bolster its guidance for supporting documentation.

For more:
- download the report, OEI-05-11-00250 (.pdf)

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