Don’t panic: With an ECM solution, Meaningful Use Attestation documentation is there when you need it

Imagine you log onto your computer one morning and see an email from Figliozzi and Company – a name you don’t recognize. Do you open it and read it, or figure it’s spam and delete it? Most of us wouldn’t hesitate to hit the delete button. But in this case, you might regret it.

At a recent conference, I spoke with several hospital representatives who have received this email and did just that. They later learned that this message was definitely not an ad.

In fact, Figliozzi and Company is the name of the audit firm chosen by the Centers for Medicare & Medicaid Services (CMS) to audit payments and establish compliance with Meaningful Use standards. When a hospital is chosen for an audit, they are sent an email letter requesting documentation of compliance with Meaningful Use standards – and given a two-week timeframe to produce it.

Now imagine the way your heart jumps into your throat when you realize you didn’t respond to the first email and you have to scramble to produce all that required documentation.

Proof in the paper

The good news is that CMS gives guidance on its website regarding what documentation will be requested for an audit. Unfortunately, the advice is essentially to keep everything – all documentation that supports the Meaningful Use and quality measure data submitted during attestation may be needed for an audit. CMS also encourages organizations to “save any electronic or paper documentation that supports your attestation.”

These reports and documentation become as valuable as gold to a hospital or physician practice. They prove your organization’s attestation that it met government standards for Meaningful Use. Much of this documentation cannot be reproduced, and so it is extremely valuable. However, it can be difficult to manage.

After organizations create reports and documentation, they often store them in binders full  of paper in secure locations. The challenge for your organization is that there is one copy of your documents housed in one location, and only one person can access this data at a time. Adding new reports or information to these binders has to be done manually.  The whole process of maintaining these paper binders is time-consuming and cumbersome.

A secure solution

But, it can be streamlined and simplified. By utilizing an enterprise content management (ECM) system like OnBase, folders and sub folders are created electronically to facilitate organization of the documentation. Reports are imported directly into the ECM system, without printing and scanning, and indexed for easy retrieval. Printed reports can be scanned into the system and indexed as well. With ECM, you have your information housed in a secure and accessible format in a very short time. The risk of losing information through a disaster is gone, security of sensitive information is assured, and the dread of an audit is reduced.

For example, I’ve heard from many hospitals about the challenges of proving that the Clinical Decision Support rules were configured for the whole attestation period.  ECM addresses this by storing screenshots of settings within the system to indicate that these rules are on. These screen shots can be updated using versioning to show compliance with this measure throughout the attestation period.

User security can also be set within an ECM system so that all appropriate employees can access and retrieve necessary documents. Maintaining an electronic file of all Meaningful Use documentation gives users the confidence that the data is at their fingertips when needed.

If cost is a concern, a reputable ECM vendor will offer solutions to fit your needs and budget. Whether you take advantage of a hosted system or subscription services, you’re freeing up your IT resources and avoiding the expense and complexity of onsite hardware.

Back it up

As Clinicians, our saying has always been “If it’s not documented, it isn’t done.” Don’t let all of your hard work in meeting Meaningful Use standards be for naught by failing to have the documentation to back it up.

With an ECM solution in place, even if you delete that first email from Figliozzi and Company, you can rest assured that the documentation you need to provide within that two-week deadline will be accessible and organized.

If you interested in having this conversation, feel free to contact me at [email protected].


As a registered nurse for more than 30 years, Lorna Green, RN, BSN, worked in a number of healthcare environments – including ICU, Surgery, Home Health and Medical/Surgical Units and as a school nurse – before transitioning to informatics and Health Information Technology in 1999.

As Hyland’s Healthcare Informatics Executive Advisor, Lorna provides thought leadership and expertise of the regulations, solutions and trends impacting the informatics discipline within healthcare industry, specializing in clinical processes and quality measures, the Joint Commission standards, Meaningful Use, Interoperability and the HIMSS Analytics EMR adoption model.

Lorna earned her bachelor’s degree in nursing from Valdosta State University in Georgia. She joined Hyland in 2010 as a Senior Business Consultant.
Lorna Green

Lorna Green

As a registered nurse for more than 30 years, Lorna Green, RN, BSN, worked in a number of healthcare environments – including ICU, Surgery, Home Health and Medical/Surgical Units and... read more about: Lorna Green