Deluge of Meaningful Use Audits
By Jim Tate, EMR Advocate
Meaningful Use Audit Expert
Twitter: @JimTate, eMail: audits@emradvocate.com
When it rains it pours. In West Africa it is called the monsoon. In Costa Rica it is the green season. Growing up in Georgia we just called it a gully washer. Whatever you call it, there seems to be a virtual storm of meaningful use (MU) eligible hospital (EH) audits popping up all over the country in the past month. In the last week alone I have heard of numerous hospitals receiving the infamous “audit engagement” letter. Here are a few anecdotal examples of what is being called the “October surprise”:
- During a call this week with a colleague in Nebraska I was told he had been contacted in the past week by no less than 5 EHs that needed his help responding to audits.
- An HIE executive in Indiana mentioned they were aware of four area hospitals that had received the audit notice in the past two weeks.
- An executive of a large hospital group in New York called me this week asking for guidance. Two of their four hospitals had been audited in October.
- The College of Healthcare Information Management Executives (CHIME) after becoming aware of a new spate of audits, sent out a survey to their membership. They discovered that out of 1,400 member organizations, almost 100 received audit notices in October. That works out to more than 6% of their member hospitals being audited in one month. T.S. Eliot said that April was the cruelest month, but October seems to be in the running. More details on the CHIME experience are available here.
Bob Dylan said it best almost 50 years ago in The Ballad of a Thin Man, “And something is happening here, but you don’t know what it is, do you, Mister Jones?” Yes, something is happening here and it may be too early to tell if the focus of the MU audits is moving from the eligible professionals to the eligible hospitals or just a general ramp up is occurring across the board. Might be good to dust off those 2011 attestation documents and just be sure all is in order in case the “October surprise” is here stay.
I’ve place a number of educational resources on the MU audits and appeals on my website and if you have a specific question feel free to contact me.
Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. His unique combination of skills has brought successful outcomes to hospitals at risk of having their CMS EHR incentives recouped. He led the first appeal challenge in the nation for a client hospital that had received a negative audit determination. That appeal was decided in favor of the hospital. He has also been successful in leading the effort to reverse a failed appeal, even after the hospital had received notification of the failure with the statement, “This decision is final and not subject to further appeal”. That “final” decision was reversed in less than a week. If you are a hospital with questions or concerns about the meaningful use audit process, contact him at: audits@emradvocate.com.