MISSOURI’S EHR AUDIT CONTRACTOR

June 8, 2015

Brown Smith Wallace LLC, Missouri’s EHR Audit Contractor

As part of the ongoing program to monitor MO HealthNet’s Electronic Health Record (EHR) Incentive Program payments, the Missouri Department of Social Services has contracted with Brown Smith Wallace LLC  to conduct reviews of payments made to participating hospitals and professionals for program year 2013.

 

Federal regulation 495.368 requires States to comply with Federal requirements to combat fraud and abuse.  Brown Smith Wallace LLC is authorized to conduct post-payment audits through desk and/or on-site reviews.  Selected hospitals and professionals will receive a letter of notification indicating that they have been chosen for a review.

 

The purpose of the audit is to validate certain information utilized as the basis for dispersing an incentive payment, including information used in eligibility determinations and hospital payment calculations. Section 1903(t)(2) of the HITECH Act states that all Eligible Professionals and Hospitals need to meet certain patient volume thresholds in order to be eligible for Electronic Health Record incentive payments.

 

Information Required of Eligible Professionals and Hospitals

The following information may be required from eligible professionals and hospitals. A tip sheet with more detailed descriptions is referenced in the last bullet under each heading below.

 

Eligible Professionals:

Detailed encounter listing to support the numerator and denominator utilized in the eligibility calculation, Documentation to support an eligible professional’s affiliation with locations for which patient encounter volume was reported, Documentation to support an eligible professional’s affiliation with a group practice when that eligible professional utilized the group proxy to report encounter volume, and When appropriate, documentation to confirm the provider or provider organization had a legal or financial obligation to the Certified Electronic Health Record Technology at the time of A/I/U (Adopt, Implement, or Upgrade) attestation. A tip sheet for eligible professional: https://dss.mo.gov/mhd/ehr/pdf/post-payment-review-tips-eligible-professional.pdf

 

Eligible Hospitals:

Detailed encounter listing to support the numerator and denominator utilized in the eligibility calculation, Documentation to support discharges according to the applicable cost reports or other documentation utilized in calculating the growth rate and discharge-related amount, Documentation to support the Acute Medicaid Days, Acute Medicaid HMO days, and Total Acute days utilized in calculating the Medicaid share, Documentation to support Charity Care Charges and Total Hospital Charges utilized in calculating the Medicaid share, and When appropriate, documentation to confirm the hospital had a legal or financial obligation to the Certified Electronic Health Record Technology at the time of A/I/U (Adopt, Implement, or Upgrade) attestation. A tip sheet for eligible hospitals: https://dss.mo.gov/mhd/ehr/pdf/post-payment-review-tips-eligible-hospitals.pdf

TELEPHONY TRACKING SYSTEMS UPDATE

June 5, 2015

The following is from a memo published by the Director of the Division of Senior and Disability Services on May 26, 2015 regarding the requirement for Telephony Tracking Systems.  Click HERE to download the full memo.

 

“Effective July 1, 2015, pursuant to Sections 660.023 and 208.909, RSMo, all In-Home Services and Consumer Directed Services providers are required to have, maintain, and use a telephone tracking system for the purpose of reporting and verifying the delivery of all In-Home and Consumer Directed Services as authorized by the Department of Health and Senior Services (DHSS). The telephone tracking system must meet the applicable requirements of Sections 660.023 and 208.909, RSMo.

 

The telephony pilot project ended when the completed report was provided to the general assembly in 2013. Therefore, Missouri Medicaid Audit and Compliance (MMAC) will no longer provide a list of telephony vendors who were approved for participation in the pilot project. Home and Community Based Services (HCBS) providers are no longer required to complete an addendum when they begin telephony. MMAC will add an attestation statement to the provider agreements beginning July 1, 2015.

 

Pursuant to Sections 660.023.3 and 208.909.5(4), RSMo, DHSS will be drafting a regulation regarding telephony. DHSS will be working closely with MMAC and the HCBS provider associations to gather input and feedback. After the rule is drafted, there will be a public comment period.

 

Additionally, if you are looking for information regarding telephony vendors that others in your industry are using, the associations will be able to assist you.

 

The statutory requirement for using telephony does not apply to Residential Care Facility Personal Care providers, Adult Day Care Centers, or Home Health providers.”

 

MMAC is committed to working with the provider industry and the Department of Health and Senior Services to assist our providers with the implementation of telephony.  As the memo states, MMAC will no longer require an addendum, as this was part of the pilot project.  We will not have a list of telephony vendors published on our website.  We will add an attestation statement to the provider agreements beginning July 1, 2015.

 

MMAC will incorporate telephony requirements into its pre-enrollment on-site visits, and its on-site audits.  Any questions or concerns may be sent to MMAC.IHSCONTRACTS@dss.mo.gov

 

UPDATE:  (JULY 6, 2015) AT THIS TIME MMAC WILL NOT BE ADDING AN ATTESTATION STATEMENT TO THE PROVIDER AGREEMENT AS STATED ABOVE.  FOR THE LATEST INFORMATION CLICK HERE.