How to Prepare for an EHR MU Audit

Posted by KUNAL JAIN on Mar 5 2015

EHRMUAuditSo you’ve attested to receive payment from the Medicare or Medicaid Electronic Health Record (EHR) Incentive Program – great!

Now you’re probably wondering how to properly prepare your office in case you should fall under the 5-10% of providers who are subject to an MU audit. The Centers for Medicare & Medicaid services (CMS), as of 2013, have begun conducting pre- and post-payment audits in order for eligible professionals (EPs), critical access hospitals (CAHs), and other healthcare providers who are Medicare & Medicaid (single and dually eligible) to receive payment.  

In order to gain the knowledge needed to prepare, it is important you know what CMS and its contracted CPA, Figliozzi and Company, are going to be looking for. This is for Medicare only, as Medicaid audits are funneled through individual state-hired contractors.

This knowledge will empower your office to monitor files and ensure all of your supporting attestation documentation reaches and transcends meaningful use (MU) parameters and anything else Figliozzi and Company may require.

What is Meaningful Use?

For EPs participating in the Medicare or Medicaid EHR Incentive Program, there are 3 Stages of meaningful use – objectives in order to reduce healthcare discrepancies – which providers must follow while using certified EHR technology in order to receive funding from CMS. This funding happens over a five to six year period once professionals become a participant and submit attestations.

This incentive program wants you to participate, and is simply ensuring money is getting routed to the proper places and the information and figures you provided are in line with what you are expecting to receive back. These figures are usually measured in percentages based on the documentation you used to attest to meaningful use.

Some requirements of Stage 1 Meaningful Use include the following:
  • Reports that generate the numerator and denominator values for your measures (usually provided on certified EHR software)
  • Using CPOE (computerized physician order entry) for medication orders
  • Implementing drug-drug and drug-allergy interaction checks
  • Record demographics
There are deadlines depending on what Stage of meaningful use EPs are submitting for (check out our excerpt about the extended deadline here).  According to CMS’s Stage 2 Overview Tipsheet, exceptions are being made for those who switched in 2014 to allow time to “align with existing CMS quality measurement programs.”

What do I Need to Provide for the Audit Specifically?

Now that you know what is required by CMS and how it is being gauged through meaningful use, you can take the next steps in order to prepare the process of an audit. Take these steps, and as long as your numbers and efforts are truthful and in good faith, your chances of problems will lessen significantly:

1. If CMS contacts you, be prepared for a quick turnaround time. Your due date to respond back is 14 days from when they contact you, so make sure you communicate with your office manager/whoever runs your EHR to ensure your reports are accurate in conjunction with what you used to attest to meaningful use.

2. Save a copy of your reports via paper or digital screenshot and be prepared to “provide a summary of the data that supports the information entered during attestation” according to CMS’s website. Some EHRs change reports based on cycles, so make sure you are familiar with how your software processes information so you can provide extra support to your attestation.

3. Be ready to provide risk security analysis. This is a common error, and is best described as congruent with HIPAA’s (the Health Insurance Portability and Accountability Act) guideline requirements for providers. Instead of every two years like HIPAA, however, MU requires you provide this during every reporting period (nothing extra, just on a more frequent basis). Make sure you conduct the analysis before the end of the cycle and that it is traceable back to your specific EHRs and practice to steer clear of problems.

Key Takeaway

If by some chance post-audit you are not seen as a meaningful user, your practice or hospital will not receive funding for the duration of that reporting period.

Don’t worry, as CMS is open to helping practices with the auditing process! You may contact them and go to their website for more information on meaningful use requirements and incentive specifics. As long as you are proactive with your EHRs and document everything correctly and in good faith like mentioned before, you increase your chances of reaching the meaningful use percentage and receiving your funding without any issues.

 

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Topics: meaningful use in 2015, EHR, electronic health records

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