By Jim Tate, EMR Advocate
Meaningful Use Audit Expert
Twitter: @JimTate, eMail: jiimtate@emradvocate.com
My recent post (The Open Secret of Health Information Technology – The Emperor Has No Clothes) lamented the fact that it is often extremely difficult to pry critical Clinical Quality files (QRDA-I and QRDA-III) out of an EHR. Well, it is time to name names, or at least one name. Yep, time to turn over a few rocks and see what dwells there.
Mandatory Disclosures
One of the best things that that 2014 Edition ONC Certification brought to life was the requirement of “Mandatory Disclosures”. 2014 ONC certification rules mandated that – “Developers must make a comprehensive disclosure of all known material information regarding their certified health IT—including limitations and additional types of costs.”
In terms of costs the developer (vendor) does not have quote a price publicly but must state whether there is a cost. Kudos to whoever required these disclosures to be made available online at the Certified Health IT Product List. In the nooks and crannies at that site you can find Test Results, Usability Reports, and Mandatory Disclosures.
Costs & Limitations Statement
So, let’s mosey over to the CHPL and see if eClinicalWorks is making the QRDA files available to providers with additional charges. For 2014 Certification eCW had to prove they could generate the QRDA files, but what if a provider wanted to obtain the files for Clinical Quality analysis or submission? Would there be a price to pay? You bet there is. Here is the text directly from eCW’s required Costs & Limitations Statement.
“Generating and/or transmitting a QRDA or other format file(s) required participation in payer quality initiatives/programs may require one-time file generation costs, multi-file generation costs and/or consulting fees.” This is in regards to criteria 170.314(c)(3) Clinical Quality Measures – Electronic Submission.
There is certainly no reason eCW can’t charge for this, but it certainly does not meet the spirit of open data or healthcare data interoperability. Taxpayers have invested tens of billions of dollars to incentivize the use of electronic interoperable healthcare systems. eCW has been one of the primary beneficiaries of the money that has flowed to providers. With all that news about eCW in the last few months, this might be a good time to take the high road and free up that data.
Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. His unique combination of skills has brought successful outcomes to hospitals at risk of having their CMS EHR incentives recouped. He led the first appeal challenge in the nation for a client hospital that had received a negative audit determination. That appeal was decided in favor of the hospital. He has also been successful in leading the effort to reverse a failed appeal, even after the hospital had received notification of the failure with the statement, “This decision is final and not subject to further appeal”. That “final” decision was reversed in less than a week. If you are a hospital with questions or concerns about the meaningful use audit process, contact him at: Inquiry@meaningfuluseaudits.com. This article was originally published on My Mips Score and is republished here with permission.