Eligible Providers: Meaningful Use Audits

It comes in the mail:  “This letter is to inform you that your organization has been selected by the CMS for an audit of your facility’s meaningful use of certified EHR technology for the attestation period. Attached to this letter is an information request list. Be aware that this list may not be all-inclusive and that we may request additional information necessary to complete the audit.”

In the past several few weeks I have been contacted by numerous EHR vendors and more than a few clinical practices, large and small, who have received similar letters from Figliozzi & Company. This is the entity that has contracted with CMS “to conduct meaningful use audits of certified Electronic Health Record (EHR) technology” and have “the right to audit and inspect any books and records of any organization receiving an incentive payment.” I imagine some providers are receiving the audit letters based on their “risk profile” and suspicious entries made during the attestation process. There may also be random providers selected for the audits. Whistle blowers? To tell you the truth, I don’t fully understand why providers are being selected.

Typically there is a deadline of two weeks to supply the requested information via mail or electronic upload.  And what is being requested? Among other things:

• Proof of possession of a certified EHR technology system
• Documentation that proves that 50% or more of patient encounters during the reporting period were entered into a Certified EHR Technology system.
• For both the Core and Menu Set Objectives/Measures: supporting documentation used during the attestation.

Basically what is being requested is documented proof of everything you claimed when you applied for the CMS EHR incentives. I hope you have a folder in the bottom of a drawer somewhere that has all the required information you are going to need. Hopefully you are able to produce from your EHR a report that details the numerators and denominators for each percentage based measure during the reportable period you claimed. This will be compared with data the auditor has from your initial online attestation. If you numbers do not match you will have some explaining to do. There are some legitimate reasons the numbers might not match. I’m just hoping for the provider’s sake that careful attention and due diligence was applied during the documentation of meaningful use and subsequent attestation.

[Related Article: New Report Calls for More EHR Incentive Oversight]

More problematic might be producing the required documentation for a few of the “yes/no” meaningful use measures. Can you prove you performed one test to “exchange key clinical information”? Can you supply proof that a security risk analysis was performed before the end of your reporting period? If you claimed  an exclusion for Syndromic Surveillance can you document an acceptable reason for exclusion? If your auditor is not satisfied with your initial documentation you can rest assured that you will receive a detailed request for more specific information.

My advice if you receive one of the valentines from Figliozzi & Company? Immediately seek assistance from someone familiar with meaningful use achievement, documentation, and attestation. This could be your EHR vendor, a Regional Extension Center, or a consultant. Don’t miss any deadlines. Don’t hesitate to ask for clarification if you don’t understand what is being requested by the auditor. Read carefully the FAQ provided by CMS on audits. If you have been involved with a CMS EHR incentive audit I would like to hear about your experience. Please contact me at: jimtate@emradvocate.com.

Jim Tate is founder of EMR Advocate and a nationally recognized expert on the CMS EHR Incentive Program, certified technology and meaningful use.