Preparing to attest for meaningful use of an EHR? Be sure to have all records in one place.
CMS announced last month it would conduct another round of payment audits for up to one out of ten physicians and other healthcare professionals attesting for meaningful use.
These “prepayment audits,” announced by the CMS Office of E-Health Standards and Services in March, come on top of post-payment meaningful use audits initiated in the summer of 2012, the American Academy of Family Physicians (AAFP) reported.
According to CMS, between 5 percent and 10 percent of all eligible professionals attesting for meaningful use will be selected for prepayment audits and selections will be made both randomly and also based on protocols that identify suspicious or anomalous attestation data. Post-payment audits will affect another 5 percent to 10 percent of physicians and other healthcare professionals, the AAFP reported.
So how do physicians prepare for the audits? A number of experts have weighed in.
1. Put someone in charge: Practices should designate one person to regularly check that all responsible parties are complying with meaningful use attestation guidelines, suggests health IT consultant Beverley Caddigan of BevTek Solutions. Practices should also make sure their data and documentation is securely backed up. “Secure back ups are those that are saved and re-written regularly on physical or cloud servers with fail-over and redundancy built in,” said Caddigan. “Every practice should have two-way data information practices in place, and use good firewalls.”
2. Look at reports before you submit. “When you attest, just don’t do anything crazy,” wrote EMRAdvocate president Jim Tate in his weekly e-mail dispatch. Specifically, Tate advised providers not to “report different numbers of ‘unique patients’” for different meaningful-use measures. “Don't claim you have a certified EHR unless you really have one. Don't say you have performed a security risk analysis unless you can produce it. If you have multiple EPs in your practice it is probably not a good idea to report the exact same numbers for every provider during attestation.”
3. Be ready to respond immediately: Physicians selected for an audit will receive a letter from Figliozzi & Co., a certified public accountant firm based in Garden City, N.Y., and selected by CMS in April 2012 to conduct audits associated with the programs. Any physician who receives an audit letter should respond to the request immediately because the bonus will be held until the physician passes the audit review, a CMS spokesperson told reporters last month. Healthcare providers will have two weeks to produce necessary documentation.
4. Retain supporting documentation: All providers attesting to receive an EHR incentive payment for either the Medicare or Medicaid EHR Incentive Program should retain all relevant supporting documentation (in either paper or electronic format) used in the completion of the Attestation Module responses, states CMS. Documentation to support the attestation should be retained for six years post-attestation. Documentation to support payment calculations (such as cost report data) should continue to follow the current documentation retention processes, the agency said.
5. Prepare to Share Screen Shots, accommodate a visit: Physicians should be prepared to capture dated screenshots — copies of what appears on a computer screen — that document, for example, a test exchange of patient data with another clinician or any other software function that Figliozzi wants to verify, according to MedScape. After an initial review of the submitted documents, auditors may request additional information and even visit a physician office to see a demonstration of its EHR system, according to CMS.
Finally, practices should check out the meaningful use audit FAQs put out by CMS. These give a little more detail in terms of how practices should prepare. We'll provide more guidance as it becomes available.