The Summer of EHR Incentive Audits
EHR Incentive Audits Heating Up
by Jim Tate
Ah, summer. I love the sound of that word, “summer”. It rolls off the tongue like warm Tupelo honey and bring backs memories of my childhood. Those golden hours spent with my cousins at a lake cabin where every day blended into the next in a complex pattern of laughter, comic books, and nature. Those were the best of times, the pleasure was in simple things. I treasure my adult journeys to the Mayan temples of Chichen Itza, the Forbidden City of the Chinese Emperors, and the view of the Mediterranean from Monaco at dusk. However, they don’t hold a candle to childhood time spent with family and friends in a cabin on a lake. Even now, late at night, just before sleep comes, my mind often courses back through the years and I hear the call of the loon. It doesn’t get any better. Summer.
Thank you for letting me take a brief journey down memory lane. Unfortunately, for some this will be the Summer of EHR Incentive Audits. We knew they were coming, we heard the footsteps, and now every vendor and provider knows someone who has received an audit based on their CMS EHR incentive attestation. Both pre-payment and post-payment audits are arriving on the wings of emailed “audit engagement” notifications. I have received many call from providers who are undergoing audits based on a 2011 attestation. That can be tough because back in those pre-historic days there were giant knowledge gaps, abundant mis-information, and a sense the incentives might disappear so it was best to move fast and worry later. Well, later is now and missing or non-existent documentation could really throw a kink into your summer plans.
I have been working with a number of hospitals undergoing audits and one that only contacted me after they had failed their audit and were facing a recoupment of all incentives. Thank goodness there is an appeal process that can offer one more chance to meet the meaningful use expectations. An eligible provider can probably survive giving back $15K or $18K but it is a different story for an eligible hospital. There is serious money on the table. Imagine you are a 30 bed hospital that received over $1,000,000 in EHR incentives in 2011 and you fail your audit. In a matter of weeks you will receive a demand letter for the entire incentive. That could be catastrophic.
Let me toss out a few thoughts and resources that might help your prepare for and address a potential EHR Incentive audit:
Security Risk Analysis: It is estimated over half of eligible professionals who attest do not meet this required measure. CMS knows this. The auditors know this. Just do it and review it every year. It is not a check list. It is not taken care of by your EHR vendor. It is up to you. If need somebody to do this for you quit putting this off and contact Health Security Solutions.
Best Practices for Incentive Audits: Last month I recorded a webinar entitled “How to Survive or Avoid an EHR Incentive Audit“. Might be a few helpful tidbits there for you.
Educational Posts and CMS Audit Information: I have placed an EHR Incentive Audits resource page on my website with links to forms, documentation requirements, and fact sheets.
Have a good summer. Hope to see you at the lake.