The Centers for Medicare & Medicaid Services (CMS) conducts prepayment and post-payment meaningful use audits. Some are random; some are based on complex algorithms. If you participate in the meaningful use program, document everything indicating that you have met all meaningful use criteria.
TMA has these recommendations to help you:
- Take screen shots of electronic health record (EHR) reports indicating you met a meaningful use measure. If you try to re-create a report at a later date, the EHR may return a different result.
- When the meaningful use criteria specify "more than," that doesn't mean "equal to." For example, if the criteria indicate you need to record demographics for more than 80 percent of your patients, then your denominator and numerator should be such that they don't total 80 percent. They must total more than 80 percent.
- Keep a meaningful use file (paper or electronic) with all documentation, and know where that file is. Staff turnover could mean the person who created the file is no longer working for you when the audit request comes.
- CMS sends audit requests via email to the email address you used when registering for the meaningful use program. Be sure this email address is active and regularly checked.
The Garden City, N.Y., accounting firm Figliozzi & Co. conducts the audits for CMS. The firm sends letters via email asking for documentation supporting the meaningful use attestation.
Physicians and others selected for the audits have two weeks to submit their documentation. The audits don't involve site visits. If you need more time to gather the documentation, request an extension.
For questions about audits, the meaningful use incentive program, and other health information technology matters, contact TMA's Department of Health Information Technology at (800) 880-5720 or by email.
Action, Jan. 18, 2016