12/26/2013    Alan Bass, DPM

Audit-Proofing Measure 15 (Jack A. Reingold, DPM)

As a very early adopter of electronic health
records (beginning my 9th year soon), and
beginning my 4th year of data collection for the
meaningful use incentive program, I am keenly
aware that the government is looking for any way
to recoup the money that that have paid out to
eligible providers and one way is not having
"buttoned up" Core Criteria #15.

Many people are not aware that Core criteria #15
really is composed of 3 separate issues that must
be done in order to meet the requirements for
having performed #15. These issues are 1) a risk
analysis of the infrastructure of computer system,
2) PCI compliance (if you accept credit cards in
your practice and 3) an up-to-date HIPAA manual.
The most important thing for anyone reading this
to remember is that you should not try to do this
on your own. It's not about just having a HIPAA
manual. We are podiatrists, not I.T.
professionals. Leave this issue to the experts.

As a TRAKnet user, the research that the new
owners have done to make sure that all their
clients are protected is incredible. TRAKnet has
vetted 2 separate companies, with national
reputations, that when I contracted with them were
able to provide me with cost-effective,
comprehensive remote solution to all the
requirements for Core Criteria #15.

These companies provide more than just answering
a questionnaire and providing a manual and also
there is no need for an expensive on-site visit.
These companies are there for guidance if you are
unlucky enough to be audited for compliance with
the meaningful use program.

If you are a TRAKnet user, before you attest for
your meaningful use incentive money, I urge you to
contact them right after the Christmas holiday to
find out about these two companies. Don't get
caught not having met the requirements.

Alan Bass, DPM, Manalapan, NJ,
abassdpm@optonline.net

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