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How to Properly Prepare for a Meaningful Use Audit

By Kyle Murphy, PhD

A meaningful use expert explains what must eligible providers need to do in order to to prepare for a meaningful use audit.

- Over the past two years, eligible professionals (EPs) and hospitals (EHs) receiving EHR incentive payments have faced meaningful use audits from federal investigators (FIs) working on behalf of the Centers for Medicare & Medicaid Services (CMS).

To date, EHs and EPs have been the subject of over 650 and 10,000 unique audits, respectively, with varying degrees of success. Whereas hospitals have had a low failure rate of 4.9 percent for 613 completed audits, professionals have failed in 21.9 percent of approximately 8,000 completed audits.

Based on these outcomes, audits are here to stay, claims Inland Northwest Health Services Senior Director of Clinical Applications Mary Cheadle, RN. “We’re pretty sure those audit numbers are going to fly up as people are failing and money is having to be sent back,” she said during a recent EHRIntelligence.com webcast on meaningful use attestation and audits.

So what must eligible providers do to prepare for a meaningful use audit and ensure that they have sufficient evidence to defend their meaningful use attestation methodology and data? “We always recommend going to CMS, documenting the date you went, pulling off the documents you use that justify the way you’re attesting so that you have that in your great audit book,” added Cheadle.

Here’s a checklist of necessary evidence for surviving a meaningful use audit:

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Point person for meaningful use communication: For the most part is all about having the right documentation, but even before compiling this evidence it is imperative that eligible providers know who their meaningful use point person is.

“We’ve seen this come up more than once — that information from the auditors or FI have been lost in some void because a person either no longer resides there or have changed jobs and a new person is assigned to this role,” Cheadle revealed. “Some people are not getting the information that they’re being audited until the nth level, down to the week that you’re required to submit data.”

Attestation methodology: This is especially important for eligible providers choosing to include or not include their emergency departments in their meaningful use attestation figures.

Meaningful use registration: These can take a number of different forms. One form is a screenshot of the registration submission from the EHR Incentive Programs website and an email confirmation from CMS. Alternatively, some providers could receive a physical letter from CMS. For providers eligible for the Medicaid EHR Incentive Program, they should maintain the same set of records, except their letter will come from their state Medicaid agency.

Final cost report: This full report (Form CMS-2552-10) should be kept for four years as proof of the numbers used for meaningful use attestation.

Medicaid volume calculation: Providers need evidence to support their calculations as well as the methods used to determine those figures. Specific requirements may vary by state, so providers should check with their Medicaid agency.

Proof of CEHRT ownership: EHs and EPs cannot achieve meaningful use without a certified EHR technology. Proof of ownership can take of the form of a signed vendor contract or service agreement for each CEHRT used for attestation; a signed vendor letter for each CEHRT used for attestation validating date and type (complete versus modular); or other evidence such as an invoice purchase receipt or cancelled check for each CEHRT used for attestation.

CMS EHR Certification ID: This identification number is found on the Office of the National Coordinator for Health Information Technology’s Certified Health IT Product List (CHPL).

Proof of adoption, implementation, or upgrade: This is for Medicaid-eligible meaningful users whose AIU requirements require proof of one of the three options.

Allowable costs for the purchase of CEHRT: For up to seven years, providers should keep evidence of data calculations allowable costs and cost report and supporting documentation (e.g., worksheet, invoices).

Medicare Share calculation: Similarly, up to seven years, providers need to support their calculations showing their Medicare Share (e.g., worksheets, supporting statistics).

Attestation submissions: This is either a submission receipt of an accepted meaningful use attestation from CMS or a state Medicaid agency.

Other administrative evidence: Providers should also maintain documentation for confirmation of the percentage of encounters captured in the CEHRT; list of patient records for the attestation period that abides with HIPAA privacy and security rules; documentation of method chosen to report ED visits (all ED or ED observation) screenshots of all reports; and other unspecified administrative evidence if applicable.

As a general rule of thumb, EHs and EPs ought to err on the side of caution when it comes to documenting their meaningful use journey in order avoid having to return important EHR incentives to Medicare or Medicaid. In this case, more is certainly better.




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