Meaningful Use Best Practice: Prove your EHR Ownership
Were you aware that CMS audits proof of EHR ownership more than any other issue? Be prepared with proper documentation.
- Keep a copy of your contract or invoice from the EHR vendor. Make sure this information contains the product name, version and year. The contract should either explicitly state that you have purchased a complete EHR or it should list all of the modules you have purchased that meet the CMS definition of a complete EHR.
- Request a letter from your EHR vendor. The letter should identify all the modules necessary to have a complete EHR (per CMS specifications) or confirm that you own all the necessary modules.
- If you are leasing your system from a hospital or other entity, you will need to have a copy of your contractual agreement, with the EHR owner clearly identified. This agreement must include the terms of the lease and the number of licensed users in your clinic. Source:http://meaningfulusemonitor.com/Digging_Deeper.html
Regardless of EHR ownership, HITArkansas highly recommends you keep a list of all licensed users, listed by name and role, with your proof of ownership. Remember to this revise the list if you have personnel changes.
While this may seem simple, lacking adequate documentation could invalidate the attestation of an EP and could jeopardize the attestation for every EP in your clinic. Proper documentation is worth the extra diligence and can make a huge difference in an audit outcome.