Recent Changes to the Meaningful Use Audit Program
What in blazes is going on with Meaningful Use audits?
Well, here we are in the middle of the Thanksgiving to New Year’s holiday season. Time to pull the chair a little closer to the fire and reflect on the year that is slipping by. Time to visit and laugh with relatives for a few days and forget the flinty world of lists, appointments, deadlines, and accounts payable and receivable. I sit gazing out the window past the leafless trees to the hills beyond and my mind wanders on many things. I wish it could be that easy for me. Just as I slip into a golden reverie I am jolted back to consciousness with a thought firmly rooted in the digital and discrete reality of the left-brain. “What in blazes in going on with the meaningful use incentive audits?” I mean, come on now, we just learned the rules, gained a false sense of confidence, and lulled ourselves to sleep with a double dose of Thanksgiving turkey. That was that the last thing I remember.
Now we wake up from our nap and the world has turned upside down. For the past 18 months we were told all those Medicare EHR incentive audits would be coming from the good folks at Figliozzi & Company. Those emails, named so cleverly as “audit engagements”, came from a real live person whose name was on the email. Gosh, there was even contact information available. Now Medicare incentive audits are also arriving from a group aptly named the “EHR Meaningful Use Audit Team”. No names, no phone numbers, no fingerprints. Is this a secret group like Seal Team Six or maybe just an algorithm running through a database churning out letters? Some of the first folks who received these audit letters sent them to me convinced these were fraudulent. Well, they are not and CMS says so in good ‘ole FAQ 9272: “The CMS EHR Meaningful Use Audit Team performs meaningful use audits as part of the Medicare and Medicaid EHR Incentive Programs. If selected for a one of these audits, the eligible professional (EP), eligible hospital (EH) or critical access hospital (CAH) will receive a letter with the CMS logo on the letterhead providing instructions on providing supporting documentation and other required information.”
One other thing. We are also seeing “limited” meaningful use audits. After months and months of audit letters requesting all documentation used to support attestation we are now seeing a creature quite different. We still see those full requests but sprinkled in there now are audits focused on sometimes only one particular measure. So we now have multiple audit sources and multiple levels of documentation requests. They say things happen in threes. We have two significant changes to the CMS EHR Incentive audits and history tells me we are due at least one more.
I will be presenting at an upcoming webinar hosted by Healthcare IT News and HITECH Answers. CMS EHR Incentives: Meaningful Use Audits and Appeals for Hospitals is scheduled for January 31, 2014, 3:00 pm ET/12:00 pm PT. Click here to learn more or to register for this event. I hope you can join me as we examine this crucial topic.
Jim Tate is known as the most experienced authority on the CMS Meaningful Use (MU) audit and appeal process. His unique combination of skills has brought successful outcomes to hospitals at risk of having their CMS EHR incentives recouped. He led the first appeal challenge in the nation for a client hospital that had received a negative audit determination. That appeal was decided in favor of the hospital. He has also been successful in leading the effort to reverse a failed appeal, even after the hospital had received notification of the failure with the statement, “This decision is final and not subject to further appeal”. That “final” decision was reversed in less than a week. If you are a hospital with questions or concerns about the meaningful use audit process, contact him at: firstname.lastname@example.org.