Being very pro EHR/EMR means constantly looking for ways in which EHR’s can help your practice by improving workflow, enhancing documentation, meeting meaningful use guidelines that can add revenue to your practice. However, realistically, there is the A word that needs to be addressed. Audits by any federal, state or local authority sends shivers up most spines; but there are ways of coming through audits without the normal angst.
Of course it would be great if the Government would just take everyone at their word and trust that we are all honest and taking the time to do the extra 10-20 keystrokes and mouse clicks per patient. After all we are reporting that we are doing it, so it has to be true.
CMS is conducting pre-payment audits that begin 2013, starting with attestations submitted during and after January 2013.
According to CMS “The pre-payment audits are random and may target suspicious or anomalous data. Providers selected for pre-payment audits will have to present supporting documentation to validate submitted attestation data before CMS will release payment.”
CMS post-payment audits will be conducted by will be by conducted by Figliozzi and Company, Garden City, N.Y. during the course of the EHR incentive Programs. If selected for post-payment audit, a provider will be required to submit supporting documentation to validate their submitted attestation data.
If you are one of the ones lucky enough to have an onsite review. You should be prepared to provide a demonstration of the certified EHR system you attested with.
Here is an example of an audit letter from the CMS website.
Medicaid audits will be conducted by the states and they will have separate audit processes for their Medicaid EHR Incentive Program.
Six things you can do to insure you are ready for an audit on MU is:
1) Document what you do.
2) ONC-ATCB certification: have your ONC-ATCB certification number ready you will need it as proof that the EHR system used to meet meaningful use requirements is certified.
3) Documentation that core measures were met. (Keep the reports that you run from your EHR)
4) Documentation that menu measures were met. (Keep the reports that you run from your EHR)
5) All documentation should be retained for six years post-attestation according to CMS
6) Screen shots of non-percentage based meaningful use objectives
Tip: To verify if your EHR product is certified, please visit the ONC’s Certified HIT Product List (CHPL) for a full listing of certified solutions.