Healthcare News & Insights

How to prepare for meaningful use audits

Hospital leaders should expect the Centers for Medicare & Medicaid Services (CMS) to be more vigilant about auditing providers attesting to meaningful use of their electronic health records (EHR).  

186230717CMS received a lot of criticism from other government oversight agencies for handing out billions in incentives without thoroughly verifying that providers were consistently meeting meaningful use criteria. And since the program is still new and complex, the Government Accountability Office believes it’s at greater risk for handing out inappropriate payments, reported FierceEMR.

CMS has said it plans to audit about 5% of providers, or roughly 20,000, but it’s reasonable to expect that number to increase given this new pressure and how many providers have struggled to meet meaningful use stage 2 requirements so far.

Watching for red flags

So who will get a knock on their door from auditors?

CMS says the audits are random.

Ed Koschka, an IT leader for an Indiana-based health system, disagrees, saying there are certain red flags from providers that catch auditors’ attention.

Koschka’s system has successfully weathered several meaningful use audits, and he highlights some of the red flags that auditors might be looking for:

  • data inconsistencies, like exclusions that may contradict with patient data or measures being attested to
  • EHR systems with functionality problems
  • transitioning EHRs midyear and combining criteria scores, and
  • providers that are attesting under CMS’ new flexibility rule.

Audit preparations

Whether your facility wants to avoid attracting auditors or just wants a better chance to defend your attestation in the event of an audit, there are several steps you can take to help your hospital’s efforts going forward.

Hospital leaders should look into performing tasks like:

  • Assigning an meaningful use task force to monitor efforts, evaluate your hospital’s progress toward its goals and keep abreast of any changes to the meaningful use requirements or auditing process.
  • Maintaining ongoing meaningful use documentation. Hard evidence of how your hospital is meeting meaningful use criteria is your best defense in an audit. You’ll want to ensure there’s a system in place to make sure your facility is meeting requirements on a consistent basis. Routinely document items like security risk analyses, screen shots, reports, calculations and other EHR information to support your attestations. You’ll also want to make sure this information is stored in one centralized location so you can respond to audit requests quickly.
  • Double check your patient data compared to quality measures before attesting. For example, if you’re attesting that 30% of patients seen are Medicaid beneficiaries, make sure your data supports those numbers.
  • Train staff to recognize a meaningful use audit letter. Koschka’s facility had trouble initially because there was a long lag time between when the audit notice was received and when the necessary people were informed. Training staff to recognize letters can ensure you begin preparing promptly.

It’s also beneficial to keep an ear to the ground to see how other providers are doing with meaningful use audits, paying close attention to where others fell short so you can avoid making the same mistakes.

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