A meaningful use audit that ends badly for you could mean you have to forfeit your meaningful use incentive dollars from the Centers
for Medicare & Medicaid Services (CMS). Don’t let this happen to you.
CMS conducts both prepayment and post-payment meaningful use audits. “Some are random. Some are based on complex algorithms,” says TMA’s director of health information technology, Shannon Vogel. “If you participate in meaningful use, document everything.”
You’ll want to be able to support your attestation data for meaningful use objectives and clinical quality measures. Medicare requires you to keep documentation (paper and electronic) for six years; make sure several members of the office staff and the physician(s) know where the documentation is filed.
Ms. Vogel also suggests taking screen shots of your reports generated at the time of attestation. In addition, screen shots from your certified electronic health record (EHR) system can validate attestation for nonpercentage-based meaningful use objectives. An example is a screen shot of a drug formulary check dated from the relevant EHR reporting period.
Audit notification comes to you in an email at the address you submitted during EHR incentive program (meaningful use) registration. Ask for an extension if you need more time to respond than what’s specified in the email, advises Ms. Vogel — better to mount a thorough defense up front than have to file an appeal with CMS later. You have 30 days to appeal (from the date of the audit result notification letter) if you receive an adverse determination from the auditor.
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Published Nov. 25, 2015
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