How to prepare for a meaningful use audit

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Every practice that is receiving electronic health system incentive payments from the Centers for Medicare and Medicaid Services' Incentive Programs is subject to a meaningful use audit at any time. In order to pass an audit, eligible practices and hospitals must have the proper documents that they used in the completion of the Attestation Module responses. 

Medicaid providers are audited by states and their contractors, while Figliozzi and Company has been designated as the main contractor to perform audits by the CMS. Figliozzi and Company performs audits on Medicare-eligible professionals and hospitals, including hospitals that are eligible for both the Medicare and Medicaid EHR Incentive Programs. Those selected for an audit will be notified with a letter from Figliozzi and Company containing the CMS and EHR Incentive Programs logos on the letterhead.

According to the CMS, documentation that supports attestation data for clinical quality and meaningful use objectives should be kept and available for examination for six years following attestation. It is also crucial that you have the documentation following the current documentation retention process that supports cost report data and other payment calculations. However, these are just a few steps to survive an audit. 

The facts
Rob Anthony, deputy director of the Health IT Initiatives Group for the CMS' Office of E-Health Standards and Services, noted that more than 10 percent of organizations participating in the incentive programs will face an audit, according to the American Academy of Family Physicians. He also pointed out that, although there are organizations that are specifically targeted for an audit, most are randomly selected. Therefore, if a practice or hospital receives a letter saying they will be audited, it does not necessarily mean they have made any errors.

According to EHR Intelligence, there have been more than 650 unique audits for eligible hospitals and over 10,000 for eligible professionals. Although each audit ended in various levels of success, hospitals had the lowest failure rate, including 4.9 percent of the 613 audits completed. Professionals, on the other hand, have failed 21.9 percent of roughly 8,000 completed audits. 

Due to the tendency for so many professionals to fail their audits, it is more than likely that audits are not only here to stay, but that the number performed each year will increase.

Mary Cheadle, the Inland Northwest Health Services senior director of clinical applications, told EHR Intelligence in a recent webcast focusing on meaningful use attestation and audits, "We're pretty sure those audit numbers are going to fly up as people are failing and money is having to be sent back."

Therefore, with more audits expected in the future, it is necessary that providers and hospitals take the proper steps to ensure that if they are faced with an audit, they are well-prepared with the right documentation.

Necessary documentation for surviving an audit
If you have all of the documentation and have properly completed the attestation process, an audit should not be something to worry over.

"The first thing we always tell people is that if you've entered accurate numbers [in the MU attestation process] and have the documentation to support that, then the audit is a really simple process for this program. You're simply showing [auditors] supporting documentation," said Anthony, according to the AAFP.

Here are a few of the most important pieces of evidence that will be necessary in order to prevent failure during your audit.

1. Attestation methodology – For eligible providers choosing whether or not to include their emergency departments in their meaningful use attestation figures and calculations, attestation methodology is crucial, according to EHR Intelligence. 

2. Cost report – Your final cost report is an important piece of information that auditors look at for evidence of your numbers used for meaningful use attestation. This document should be kept for four years post-attestation. 

3. Meaningful use registration – There are several different versions of meaningful use registration you could have. One of the most common forms is a letter from the CMS confirming registration. However, an increasingly popular method is also a simple screenshot of your registration submission from the EHR Incentive Programs' website followed by an email confirmation from the CMS. Additionally, providers eligible for the Medicaid EHR Incentive Program will have received a letter from their state Medicaid agency that they should have ready to show during an audit.

4. CEHRT ownership forms – This is one of the most important forms, for neither a provider nor a hospital can meet the meaningful use objectives without the adoption of certified EHR technology, according to Healthcare IT News. There are a few possible forms for this. The first is a signed contract with your EHR vendor, or a service agreement form for all of the CEHRT used for attestation. Ownership forms can also include a letter signed by your CEHRT vendor for each system you used for attestation, validating the date and whether or not it is complete or modular. Other evidence includes a canceled check for each CEHRT used for attestation or an invoice purchase receipt.