4 Mistakes to Avoid During a Meaningful Use Audit

Attesting to meaningful use of electronic health records can give hospitals and health systems access to hundreds of thousands, if not millions, of dollars in incentive payments. However, it also opens up organizations to a meaningful use audit.

CMS engaged Figliozzi & Co., a group specializing in the audits of healthcare facilities, in 2012 to audit hospitals that have attested to meaningful use. About 10 percent of hospitals can expect to be audited each year, says Brian Doerr, senior vice president of information technology for Community Hospital Corp., and the audit selection process is seemingly random, he says.

If, during an audit, hospitals cannot meet the attestation criteria they originally attested to, CMS could recoup all of the incentive payments and even turn the case over for criminal investigation, Mr. Doerr cautions. In fact, a former hospital CFO was recently indicted for alleged fraud and aggravated identity theft violations after allegedly falsely attesting to meaningful use.

Because a failed audit can result in a major financial and legal headache for hospitals, it's important for hospitals to avoid four common mistakes.

1. Hard-to-access information. "We see hospital executives scrambling to find the documentation," Mr. Doerr says, "but can't get their hands on it when they receive the initial audit request and have 14 to 28 days to respond." Hospitals should keep their attestation documentation centralized and organized for easy review. Mr. Doerr recommends putting documents in a digital binder that multiple people know how and where to access.

2. Lack of explanations. Hospitals need to validate the information they attested to, numerators and denominators. This requires a fair amount of preparation, so hospital leaders can thoughtfully explain differences or problems in a proactive rather than reactive manner. "Check for reasonableness…and document areas where you find deficiencies after the fact," Mr. Doerr says. This can help protect hospitals during an audit process.

3. Losing continued focus. After organizations meet stage one meaningful use, Mr. Doerr often sees "a steep falloff" in focus on meaningful use. This means meetings and analysis happen much less often, if at all. "There's so much to do in hospitals that it's difficult for the team to stay focused on [meaningful use] all the time," he says. However, minutes from meetings can be helpful during the audit process, since they document the hospital's continued focus on the initiatives and outcomes.

4. Over-sharing. Hospitals can create problems or extra work for themselves in an area that CMS may not even have looked into if they over-share, Mr. Doerr says. Hospitals need to answer any audit questions thoroughly and completely, but should not offer more information than asked for. "Just because you have a lot of documentation, don't feel the need to share it all in the response," he says. "Answer the questions completely and accurately, but don't over-share." If CMS or the attorneys need further information, they will seek such in a subsequent request.

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