HHS begins meaningful use audits

August 3, 2012

Congratulations--you've attested to stage 1 of meaningful use! Next up, a possible audit request, with a limited time frame for responding. Read the details here.

If you’ve attested to stage 1 of meaningful use, you may have received or perhaps will receive a letter from certified public accounting firm Figloiozzi and Co. requesting related records. If such a letter shows up in your mailbox, open it quickly; you’ll only have 2 weeks to respond.

The U.S. Department of Health and Human Services (HHS) has asked the Garden City, New York, firm to audit the records of participants in the Centers for Medicare and Medicaid Services (CMS) EHR Incentive Program, according to a Health Law Alert newsletter article published on the Web site of the law firm Ober Kaler. CMS likely will use information from these initial, basic audits to conduct more extensive audits later, according to the article by Ober Kaler principal James B. Wieland, JD, and associate Joshua J. Freemire, JD.

Figloiozzi and Co., they say, is requesting four things from those being audited:

A copy of the certification from the HHS Office of the National Coordinator for Health Information Technology for the technology used to meet program requirements.

Documentation to support the method (observation services or all emergency department visits) chose to report emergency department admissions. “This distinction plays a large role in several of the program requirements as it determines which patients were included in the denominators of certain meaningful use core and menu items,” according to the newsletter article.

Documentation that supports the completion of the attestation module responses to core set objectives and measures. “It would appear that this request is intended to solicit information beyond that already provided to CMS as part of the attestation process,” Wieland and Freemire say.

Documentation that supports the completion of the attestation module responses as to “menu set” (voluntary) objectives and measures. “Again, the information request appears to solicit a level of information beyond that provided in the attestation documents themselves,” according to Ober Kaler.

Figloiozzi and Co. is not requesting identifiable or detailed patient records right now, Wieland and Freemire say, adding that entities being audited should provide the minimum information necessary to satisfy audit requests, so as not to run the risk of accidentally sharing information that identifies patients.

For general information on EHR Incentive Program audits, visit the CMS Web site.

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