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- Myth 1
My EHR is certified, so I automatically meet Meaningful Use Objective #14 (#15 for eligible providers): “Protect electronic health information created or maintained by the certified EHR technology through the implementation of appropriate technical capabilities.”
Recognizing that health information should be protected with reasonable administrative, technical and physical safeguards to ensure its confidentiality, integrity and availability, and to prevent unauthorized or inappropriate access, use or disclosure, our security risk assessment program is designed with the following scope and deliverables.
- Administrative – you must have policies and procedures in place that govern your EHR and ePHI (Electronic Protected Health Information).
- Technical – this applies to your certified EHR and your infrastructure.
- Physical – Do keyboards automatically lock and log off after a specific period of time? Is the infrastructure secure and locked? Is the building secure? Etc.
- Myth 2
Our clinic is part of the hospital and the provider’s bill under the hospital’s tax ID. Thus, our providers are not eligible for stimulus funds.
Not necessarily. The situation above would require a more detailed analysis by your WTxHITREC Trusted Advisor. In most cases these providers do qualify for stimulus funds. Just a couple of rules to immediately determine their eligibility:
- They cannot render 90% of their services in an inpatient hospital or emergency room hospital setting.
- They must spend more than 50% of their time in that clinic. (Note: in many rural areas a provider may work in more than 1 clinic and/or hospital).
- Myth 3
Receiving my first incentive check means my attestation, quality measures, cost data, patient data, and other submissions are correct.
Not necessarily. As posted on page 156 of the Final Rule, CMS will identify and recoup overpayments made under the incentive payment program that result from incorrect or fraudulent attestations, quality measures, cost data, patient data, or any other submission required to establish eligibility or to qualify for a payment.
Any overpayment will be recouped by CMS or its agents from the eligible provider, eligible hospital, or other entities to whom the right to payment has been assigned or reassigned. Medicare fee-for-service providers, eligible providers, and eligible hospitals will need to maintain evidence of qualification to receive incentive payments for 6 years after the date they register for the incentive program.