By Jim Tate, EMR Advocate
Meaningful Use Audit Expert
Twitter: @JimTate, eMail: inquiry@meaningfuluseaudits.com
What a difference a few weeks can make. Earlier this month I wrote a post entitled: When It Rains It Pours: A New Trend In Meaningful Use Audits? The topic was a disturbing new trend in meaningful use audits. At EMR Advocate we had been working with a hospital system to validate their meaningful use attestations by a series of mock audits. All identified gaps have been addressed by obtaining additional documents and other mitigation efforts. Last month the hospital received 33 pre-payment audits for their eligible professionals (EP) in one day. That is enough to choke the proverbial mule. Even a fully prepared hospital, as was the case, could be overwhelmed responding to that many requests for documentation.
Just in time for the weekend, good news came last Friday. The auditors, Figliozzi & Company, had been discussing with CMS the issue of a burden created by the selection of “numerous Eligible Professionals from the same practice”. We were notified of their solution to this issue: “Figliozzi & Company will be performing a sample of the universe of the Eligible Professionals selected. “
Five EPs were designated to undergo the audit and we were told: “This pilot sample will be completed on a fast track. Pending the results of the pilot sample, we will either expand the sample (if an Eligible Professional in the pilot sample does not meet Meaningful Use) or cancel the remaining audits in process (if all Eligible Professionals in the pilot sample meet Meaningful Use).”
To me this a good resolution to what could have a thorny and unnecessary process. My hat is off to those who recognized the potential problem and addressed it quickly and appropriately.
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. This post was original published on MeaningfulUseAudits.com.