CMS has paid out over $21 billion dollars in incentive payments to providers and hospitals who have successfully attested under the EHR Incentive Program (i.e. meaningful use). With that much money out the door, you can bet that Congress is watching closely to ensure that those dollars are only going to people who really have met the requirements. One way that CMS is monitoring meaningful use is by conducting audits of healthcare providers and hospitals who have attested and received incentive payments.
The prospect of being selected for a meaningful use audit can be scary, and based on the experiences of some providers who were forced to prove that they met meaningful se during an audit, the actual audit process can be even worse. For some providers, the audit process may simply involve exchanging a few documents, but for others, the process can be drawn out for months, with hundreds of documents being exchanged during that time.
Preparing for an audit
The good news is that as a provider participating in meaningful use, there are things that you can do now to help prepare your practice for a potential audit. These preparations may help your audit go smoothly and end quickly.
1. Know what to look out for when you’ve been selected for a meaningful use audit. The best way to prepare for an audit is to know what would be expected so you’re not caught off guard. If you know what the audit notification letter looks like, you’ll be less likely to panic if one arrives in your mailbox or email. Review sample audit letters posted on the CMS Education Materials website.
2. Know what documentation you will need and where they’ll come from. CMS has provided audit preparation guidance for both stage 1 and stage 2 providers, so take advantage of these resources and read them before your EHR reporting period begins. Starting looking through your EHR to find out what reports you’ll need to print and take note of what documentation you’ll need to gather at certain points during the process.
3. Talk to your EHR vendor to find out what specific resources they have available to help you prepare. Since EHR technology can vary quite a bit from system to system, it is important to understand exactly how you will prepare for an audit using your EHR. Contact your EHR vendor directly; they should be able to provide you with tailored guidance to help you prepare documentation for a meaningful use audit.
4. Train your staff to help gather documentation throughout your EHR reporting period. After you have become familiar with what documents you’ll need to collect, make sure you train your staff so that gathering and storing those documents can be a team effort. For example, you’ll want to document when patients have refused clinical summaries; if you can’t do that in your EHR, you’ll need a process for maintaining those records somewhere else.
5. Create electronic and paper copies of all the documentation related to your meaningful use attestation and store it in a safe place for at least six years. While printing a stack of documents might make you feel like you’re prepared for an audit, remember that most of the document exchange with CMS auditors will occur via e-mail. Make sure that you have both electronic and paper copies of all of your meaningful use documents that apply to your EHR reporting period and attestation stored in a safe and reliable place.
Preparing for a meaningful use audit may seem daunting, but with the right information and processes in place in your practice, you’ll be able to focus on patient care and not worry about whether you’ll be able to keep your EHR incentive payments.
Emily Richmond is senior manager, health care quality, Practice Fusion.
