This series of blog posts will add our experience with Meaningful Use Reporting, Attestation, Audits and Announcements to the best stories currently being published on these topics.
In this post we comment on a story from Jim Tate, EMR Advocate and Meaningful Use Audit Expert, (and friend of SA Ignite). Tate recently wrote an insightful article, “CMS Provides Additional Insight into EHR Incentive Audits and Appeals”, in MeaningfulUseAudits.com.
The focus of the article predicts that EHR Incentive Audits will Increase in 2014, and draws realistic conclusions from a CMS sponsored webinar held last week, attended by Tate. Quotes from Tate’s article are followed by my comments–and we encourage all meaningful use professionals to add their experiences. As the number of audits increases we can collectively provide insights, color and support for what is no doubt going to be a bumpy ride!
JIM TATE: CMS began pre-payment audits this year, starting with attestations submitted during and after January 2013. I’ve been seeing more of these pre-payment audits. Also, seeing more “limited audits”.
TOM LEE: SA Ignite has seen an increase in these audits among our client base as well. So far, pre-payment audits our clients have experienced have been relatively straightforward. However, we have heard several clients express fear about an email from CMS getting lost. Make sure you closely monitor the email address you registered with CMS for the audit notice so as not to unnecessarily delay payment.
JIM TATE: CMS will not be providing any clues as to the logic behind the selection of those providers who are audited based on an established risk profile.
TOM LEE: While there is no published guideline, we learned directly from the auditors in November 2013 some directional guidance on what the hidden logic for triggering audits may be. Possible triggers include:
Measure values with several standard deviations from the norm
Measure improvement trends that seem too fast relative to when the provider adopted an EHR
Measure data anomalies (such as different denominators being the same or different when the opposite is the norm)
See our article in Becker’s on “Health System Best Practices for Reducing Meaningful Use Audit Risk”
JIM TATE: After a failed audit many providers continue to attempt to communicate with the auditors for clarification or in hopes of reopening the audit. CMS is clearly stating that if a provider receives a negative determination, the only potential next step is the filing of an appeal.
TOM LEE: This is a spot none of us wants to be in. In such cases, we should point out that it is wise to enlist someone, such as Jim, with experience appealing a negative meaningful use audit result.
We would enjoy hearing your strategies for avoiding and/or coping with the impact of the current audit environment.
Feb 12, SA Ignite will discuss “Reducing MU Audit Risk – Real Stories and Best Practices” on a CHIME College Live Webinar for CHIME CIO members. Join us as Wellspan Health, Rush University Medical Center, and others will share their experiences.
Tom Lee can be reached at: firstname.lastname@example.org
Jim Tate can be reached at: email@example.com
Ask us how you can efficiently attest and track EHR incentive dollars. Request a demo.