By Jim Tate, EMR Advocate and Meaningful Use Audit Expert
Twitter: @JimTate
eMail: audits@emradvocate.com
Website: www.meaningfuluseaudits.com
Back in the frigid days of last winter I wrote a post entitled: 2014: CMS EHR Incentive Audit Risk – Patient Engagement and Portals. In particular, I focused on the challenges that Eligible Hospitals (EH) attempting to achieve Stage 2 meaningful use (MU) might encounter with Core Measure #6: “Provide patients the ability to view online, download, and transmit information about a hospital admission”. For EHs in Stage 1 this is totally under the control of the hospital. The measure can be met by having “more that 50% 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”. No big deal there, just push that information to the portal and always be at 100% of compliance.
The monkey wrench comes for those trying to achieve Stage 2 for this measure. EHs have to meet an additional requirement that requires motivating patients to come to the portal and at least view their information: “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”.
There is a partial exclusion available 2 for Core Measure #6 for EHs at Stage 2 but that requires the hospital is “located in a county that does not have 50 percent or more of its housing units with 3Mbps broadband availability according to the latest information available from the FCC on the first day of the EHR reporting period is excluded from the second measure”.
So the issue revolves how those Stage 2 EHs in 2014 will get more than 5% of unique patients (or their authorized representative) who are discharged to at least come to the portal and view their information? First, let me add one little tip here about that statement, “more that 5%”. Don’t count on 5.1% meeting the grade. More than 5% means at least 6%. Don’t get fancy with decimal points and rounding up. Make sure you have at least 6%. Trust me on this. OK, back to the main question. How are we going to get those patients to come to the portal? Can we do something at discharge even though at that point they are not technically discharged? Do we have to wait to they get home and promise them an Amazon gift card if they log on? Maybe throw in a fruit cake if they can get their neighbors to log on?
Thankfully a recent CMS webinar (Stage 2 Exchange Requirements – 4/22/2014) provided much needed guidance on an acceptable workflow that an EH may put in place to take care of this. During the Q/A session the host was asked if it was allowable to have a staff member demonstrate during discharge to the patient how to log into their portal account. Did this meet the MU requirement? The answer was “Yes” and spoke to recent CMS guidance that allows a patient to be pre-discharge, educated on logging into their portal account, and still have that action count as meeting the MU requirement.
Stage 2 MU patient engagement validation may cause audit issues. If you are interested in learning about our Mock Audit Services, please contact me at audits@emradvocate.com.
