07/24/2014    Michael Brody, DPM

RE: Confusion About Utilizing 2011 Software to Attest for 2014

Recently there has been some confusion about
whether providers have the option of utilizing
2011 Certified Software to attest for Meaningful
Use in 2014. This is based upon a Notice of
Proposed Rule Making (NRPM) published by CMS.
This is NOT a final rule and will not become final
until September or October and the final rule may
change and may not be the same as the proposed
rule.

Based upon the PROPOSED rule, if a provider
utilizes 2011 certified they must attest that the
vendor could NOT provide 2014 certified software
in a timely manner when they attest for meaningful
use. If a provider attests to this, and they are
audited for Meaningful Use, the auditor may find
that the vendor DID have the 2014 software
available, and it is possible that the provider
will fail their Meaningful Use Audit and will not
only have to return the incentive payment but
would be subject to a payment adjustment in 2016.

It has been my experience that providers who fail
an audit for one year are often subject to audits
for additional years of Meaningful Use. So in the
case above, should the provider fail the audit
they could find themselves a target for audits for
future and even previous Meaningful Use Periods.

If your vendor has 2014 Certified Software
available, I strongly encourage you to upgrade to
that software package to put yourself in the best
possible position to meet Meaningful Use and pass
a potential Meaningful Use Audit. Responsible
software vendors are having their clients upgrade
to the 2014 certified software to best protect
their clients from the potential negative impact
of payment adjustments in 2016 and the pain of
potential failure of future Meaningful Use Audits.

A full article that provides details on the final
rule will be published in the October edition of
Podiatry Management Magazine.

Michael Brody, DPM, Commack, NY,
mbrody@tldsystems.com

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