Meaningful Use Attestation Is Complete, Now Breathe a Sigh of Relief – Or Can You?

Pennsylvania Medical Society

By: Pennsylvania Medical Society’s Practice Support Team

Numerous eligible professionals have been working diligently to meet Meaningful Use (MU) measure objective thresholds, whether by using the Flexibility Rule or by attesting to the stringent requirements of Stage 2 in 2014.

The Pennsylvania Medical Society (PAMED) has received quite a bit of feedback from our membership regarding the MU program, and some potential problems and issues they are experiencing such as:


  • Attestation rejections related to information within the PECOS system not aligning with the information within the EHR Incentive Program Registration and Attestation System
  • EHR payment adjustment being assessed although attestation was successful
  • Prepayment audit letter received only after two days of submitting Stage 2 attestation


Let’s take a moment to discuss each one of these topics individually.


  1. Attestation rejections due to PECOS mismatch with EHR Incentive Program Registration


According to the Centers for Medicare and Medicaid Services (CMS), providers who received this rejection would need to contact their local Medicare Administrative Contractor (MAC) Enrollment department as information within the PECOS system does not match what is listed in the EHR registration and attestation system.


When researching this problem, PAMED found a direct correlation to the revalidation process. Numerous practices having revalidated one or more providers within their group, however, still had remaining providers yet to be revalidated, a scenario that seemed to have caused the attestation to be rejected. Providers still in the revalidation process also would be rejected for a PECOS mismatch. In conversation with CMS representatives, revalidation processing may range from 60-210 days. In some instances, the local MAC needed to “recycle the provider file” to correct the problem. This in turn, by the press of a button, corrected the problem, allowing the practice to resubmit its attestation. In other instances, the Electronic Funds Transfer (EFT) information for the group needed to be updated for those providers yet to be revalidated.


  1. EHR payment adjustment being assessed despite successful attestation


Imagine being a successful user of MU and receiving your 2015 Medicare reimbursements reduced by 1 percent with remittance code N700, Payment adjustment based on Electronic Health Record. Your practice never received a letter from CMS advising that your provider was subject to a penalty, your attestations were successful, and you have documentation stating such. One of your providers was audited, but the result of that audit was favorable again with supporting documentation. So, how can your practice be getting assessed a penalty?


In order to get to the root of the problem, PAMED placed a call to the EHR Information Center (888-734-6433) and is awaiting further information on this issue. At this point, we do not have any clear cut answers as to how and why this is happening. We do know that an informal review form should not be completed unless a penalty letter was received by the provider. This is an error on CMS’ end which will need to be corrected. What is unfortunate is the administrative burden the practice’s billing staff will face in reapplying the 1 percent corrected payments.


  1. Prepayment audit letter received only after two days of submitting Stage 2 attestation


We can only speculate that CMS has realized the difficulties physicians have had meeting the objective thresholds for Stage 2 due to the stringent requirements. Therefore, soon after providers submit attestation, audit requests follow shortly thereafter. Some feedback PAMED has received from its members has been audit requests received after two days of attestation to an audit request received hours after Stage 2 attestation.


Providers need to be certain to have all of their documentation ready and in hand to send to Figliozzi and Company to support all the Core and Menu objectives.  Any measures that were answered with a yes/no, screenshots, or reports from the EHR supporting that answer should be provided.


Let’s take the example of Core Measure 11, Generate patient list by specific conditions. When attesting, the system simply states “generate at least one report listing patients of the eligible professional with a specific condition.” The provider must mark a yes or no. To support this measure in the case of an audit, the practice will need to show that a report was indeed run during the attestation period to support their answer.


MU continues to be a controversial issue and struggle for many providers. Those providers who choose not to participate due to the burdensome requirements and associated costs, as well as those providers who choose to participate to avoid the associated payment adjustments to their Part B fee-for-service reimbursements, must deal with aggravating issues like those issues listed above.


PAMED has the resources to help practices meet MU requirements, earn incentives, and avoid penalties.


One of the most common causes for a failed audit is insufficient documentation of the Security Risk Analysis (SRA). PAMED has a toolkit available to assist practices in the completion of the SRA. This toolkit and other HIPAA-related resources can be found at www.pamedsoc.org/hipaa.


PAMED has educational webinars on MU, available at www.pamedsoc.org/webinars. MU incentives and penalties also will be a topic at our spring practices manager meetings across the state. Learn more and register at www.pamedsoc.org/managermeeting. Watch your email inbox for the Daily Dose, PAMED’s daily, all-member email, as it contains the latest news and resources to help you and your practice navigate the challenges you face, such as MU.


PAMED members who have questions about MU can contact our Practice Support Team at
(717) DOC-HELP, that’s (717) 362-4357.

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Allegheny County Medical Society
713 Ridge Avenue
Pittsburgh, PA  15212
412-321-5030  FAX 412-321-5323