Many providers, already swamped with too many other concerns, prefer to think that Meaningful Use audits are something that happens to other practices.
Unfortunately, that’s not true.
Trudy Bearden, a Washington & Idaho Regional Extension Center (WIREC) consultant, reports that at least one in 20 meaningful use (MU) attesters will face an audit, and half of those will undergo a pre-payment audit. Bearden addressed this subject in a recent webinar for us.
Attorney Clinton Mikel, JD, said in a Medical Economics article that he has seen anecdotal evidence that audits are occurring more frequently. “From a policy perspective, it makes sense that [audits are] increasing because it is such a hot focus area and, frankly, it’s a way to recoup money,” says Mikel, who is a partner at the health law firm The Health Law Partners.
Anantachai (Tony) Panjamapiron, PhD, a consultant with The Advisory Board Company, warned in a Healthcare IT News article that “…organizations of all sizes should treat MU audits “as a matter of when, not if.”
Panjamapiron cautioned that, in terms of preparation for the audit process, “smaller organizations tend to go with the flow and be reactive to the audit request. They often do not have a predetermined or written policy in place detailing the actions they will take if an audit letter comes.”
Since these audits are more likely than not, it only makes sense to prepare for them as you are conducting your Meaningful Use attestation, since it’s easier to do it then rather than having to circle back later and find the documentation from your electronic medical records and other sources.
A Medical Economics article entitled “Meaningful Use audits: Seven strategies to protect your practice” detailed some key items for practices to remember about these audits:
1. Assume you’ll be audited: The best thing a physician can do to ensure an audit goes well is assume they will be audited before they attest and prepare for it.
2. Handle audit promptly: It’s important to respond right away after receiving an audit letter
3. Physicians should take charge: While it is good to have a level of trust in the practice manager or other staff member, it’s always smart for physicians to verify for themselves that the work is being done.
4. Avoid discrepancies: The auditors are looking for discrepancies between what was submitted during the attestation process and what was actually done.
5. Ensure EHR certification: physicians will need documentation from their EHR vendors confirming the version of the electronic medical records system they are using, and should monitor any upgrades to their systems to ensure that changes don’t affect the certification status.
6. Documentation is key: It’s critical that physicians have an auditable source for all data used for registering and attesting to meaningful use.
7. Complete a Security Risk Assessment: A risk analysis is something all physician practices should have had in place since 2005, when the Health Insurance Portability and Accountability Act (HIPAA) Security Rule went into effect. The article includes an outline of the risk assessment process.
In order to help you ensure that you are prepared for a Meaningful Use audit, we invite you to watch our free on demand webinar, How to Prepare for and Survive a Meaningful Use Audit; just click on the banner below.