For practices that received payment for either the Medicare or Medicaid electronic health record incentive programs, the prospect of a meaningful use audit may be daunting.
If your practice received an electronic health record (EHR) incentive payment for either the Medicare EHR Incentive Program or the Medicaid EHR Incentive Program, you may be subject to an audit.
With over $21 billion dollars being distributed to the medical community, it is not surprising Congress wants to make sure those receiving the incentives are in compliance. While you may never be audited, the mere prospect may be a dizzying and daunting proposition. But the process of going through a meaningful use audit does not have to be as bad as you think. You just need to be prepared well in advance.
Preparation goes a long way toward successfully navigating the audit process and avoiding risk to your incentive program. By keeping a plan in place, your practice won’t be blindsided and you left scrambling to collect and present data.
Creating a Meaningful Use Audit preparedness plan is key. When doing so, consider the following:
Expect to be audited
Although it may never happen, you should operate under the assumption that you will be audited. Familiarize yourself with the audit notification letter that will be emailed from Figliozzi and Company, the designated contractor performing audits on behalf of CMS. Circulate a sample audit notification letter to your employees so they can recognize it and immediately pass it onto you.
Get your documents in order now!
Attached to the letter from Figliozzi and Company will be a document request list (for both prepayment and post-payment audits). The auditors will be looking for discrepancies between the original information you submitted and what is actually being done.
They will ask for:
• Proof the EHR system used to meet meaningful use requirements is certified.
• Documentation that quality measure, core, and menu objective data were accurate.
• Proof a security risk assessment was conducted and a corrective action plan has been drafted.
Be proactive. Before you are audited, make copies of both paper and electronic documents that support the meaningful use and clinical quality measure data submitted during attestation. These documents should be stored in a safe place for at least six years.
Do not procrastinate
You have only 2 weeks from the date of notice to respond and present data through an online portal. You may get penalized for not supplying the proper documents in the given time-frame.
Take charge of the process, do not leave it to your office staff
It is easy for doctors to leave the day-to-day administration to the practice manager or front office staff. In most cases, that is okay. But not when it comes to meaningful use.
Take the initiative and verify that the work is being done; don’t leave it to chance.
Ensure EHR certification
Your practice must have certified use of EHR technology on or before the date of any attestation period, approved by an authorized certification body. Simply being on the certified system prior to running meaningful use reports is not sufficient. To satisfy the certification requirements, you will need to have documentation from your vendor confirming the version you are using.
Make sure you are HIPAA compliant
Conduct a risk analysis if you haven’t already done so, and maintain a copy of the assessment. Review it carefully to make sure it is compliant with the meaningful use requirements. The CMS published fact sheet can be helpful in guiding you through the process.
The consequences can be steep if the audit finds you have engaged in intentional fraudulent activity. You run the risk of repayment or non-payment for that reporting period. It may also be referred to the FBI and DOJ for further investigation and action.
Take advantage of the audit guides available online.
Angie Walters is the Director of Accounting & Consulting Services for Goldin Peiser & Peiser, LLP in Dallas, TX. She is responsible for providing accounting, consulting and business advisory services to the firm’s clients, as well as building a CFO Advisory Services practice within the Accounting Services group. The majority of her focus is on new business development strategy within the firm’s key niche industries — manufacturing and healthcare. You can contact Angie at AWalters@GPPcpa.com or 214-635-2547.
Goldin Peiser & Peiser, LLP is a proud member of the National CPA Health Care Advisors Association (HCAA), a nationwide network of CPA firms devoted to serving the healthcare industry. Members provide proactive solutions to the accounting needs of physicians and physician groups. For more information contact the HCAA at firstname.lastname@example.org.