By Jim Tate, EMR Advocate
Meaningful Use Audit Expert
Twitter: @JimTate, eMail: audits@emradvocate.com
What is would be like to open your inbox and find 33 separate CMS EHR Incentive audits? That is the exact experience one of our client hospitals experienced several week ago. Only forethought by the administration and diligent work by the staff is turning what could have been a nightmare into just a time consuming inconvenience. It could have been worse, much worse, but they were well prepared.
These were pre-payment audits based on 2014 attestations. Was this wave of audits received by the hospital on behalf of their eligible professionals (EP) and anomaly? I thought so until several days later I was notified of another hospital that had been the recipient of a similar notice of over 50 EP audits. What is going on? Even the most prepared hospital would be sorely taxed by such a large volume of audits hitting the inbox with the same response deadline.
The vast majority of eligible hospitals (EHs) have taken advantage of the CMS EHR incentive program. In addition, many of those same EHs have relationships with practices and clinics with EPs that are also able to participate in the incentive program. Our team at EMR Advocate had worked with the hospital in question through a mock audit process for both EH and EP 2014 attestations. Part of that process was the development of a robust “book of evidence” that would provide necessary support in case of an audit. Little did we know those books of evidence would be needed shortly after the attestations were submitted.
The hospital team that had been involved in the mock audit came quickly together and the pre-planned response process was put into play. There was no need for a mad search to locate items requested by the auditor. There was no confusion as to how to upload documents to an auditor’s portal or the best format to use. All this had been streamlined during the mock audit. Even the tricky non-percentage based measures of Public Health had well vetted supporting proof of meeting those measures. If there is a lesson to be learned it is in the area of preparedness. The hospital team took what was learned during the mock audit and put it into play immediately. That made all the difference. You never know when you might receive notification of a CMS EHR Incentive audit, much less over 30 of them. If you feel a mock audit by an outside group might help your hospital be prepared, let us know. We are always glad to talk.
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 article was originally published on Meaningful Use Audits and is republished here with permission.