A Step-by-Step Guide to Surviving a Meaningful Use Audit

ENT practices face several levels of potential Meaningful Use audits as part of the Medicare/Medicaid EHR incentive programs. The providers must demonstrate Meaningful Use through core measures, menu measures, and clinical quality (including the reporting of numerator, denominator, and exclusions). Additionally, providers must save the documents used to make the attestation for at least six years as evidence to substantiate the audit.

Most experts conclude that preparation is necessary to survive a Meaningful Use audit, and we’ve made that easy for you with our step-by-step guide.

Step 1: Understand Meaningful Use Attestation

In order for the provider to attest, demonstrate required Meaningful Use, and receive incentive payments under the EHR incentive programs, it must agree with several key statements using an online CMS Attestation System.

Once the practice completes the attestation, it qualifies for payments. Providers must acknowledge that the information submitted is:

• Accurate according to the individual(s) submitting information on behalf of the provider
• Complete with numerators, denominators, measures, and exclusions that apply to the practice
• Inclusive of data on all patients to whom the measures apply and was outputted from a certified and named EHR technology for clinical quality measures

Step 2: Understand Why the Meaningful Use Audit Program Exists

A provider receiving payments for Medicare or Medicaid EHR Incentive programs may be audited to mitigate and reduce fraud or abuse risks. In post-payment audits, providers may be requested to submit specific documents, including EHR screenshots, EHR-generated reports, or patient rosters. CMS may also require the provider to submit to pre-payment audits to include random provider selections as well as anomalous or suspicious data.

There are two basic types of provider audits:

1. The Medicare Audit, which focuses on documentation to meet Meaningful Use measures, performed by an audit firm or CMS auditors.
2. The Medicaid Audit, which varies by state but typically focuses on volume eligibility requirements for the receipt of Medicaid payments and Meaningful Use measures,

Many Meaningful Use appointments are “desk audits.” The scope of the examination of documents and records is limited and conducted off-site from the place of business. A desk audit can occasionally prompt a field audit, but this is a rare occurrence.

Step 3: Understand Audit Notifications

ENT practices selected for a Meaningful Use audit receive a notification with the CMS logo on it, including details about required documents and information. The ENT practice must respond to the audit notice within two weeks.

If the practice fails the audit, it must return all incentive payments received. False attestations can be regarded as the potential basis for liability under state laws or the Federal False Claims Act.

Step 4: Prepare for a Meaningful Use Audit

After submitting the initial attestation to CMS, the provider should make documentation and reporting measures routine. Attempts to assemble required documents, screenshots, and risk assessments in a short period are likely to fail.

Similarly, changing last year’s date to this year’s date on audit file documents and reports is a bad idea. The ENT practice must assign audit preparation to an appropriate manager. The manager should identify and break down all tasks, documents, and reports needed to achieve Meaningful Use compliance.

The practice should also engage in mock Meaningful Use audits to determine how prepared it is to undergo an actual audit.

Step 5: Avoid Meaningful Use Audit Red Flags

While some audits are chosen at random, there are some chosen based on red flags in the ENT practice’s reports, such as:

• The entire practice showing 100 percent across the board. Be honest in reporting your numbers and do not attempt to guess at what your percentages are.
• Having multiple EHR vendors. Avoid using more than one EHR vendor or vendors known to be problematic.
• If the denominators submitted do not match the population of industry standards for patients seen during the time of the reporting period.

Taking the time to understand the Meaningful Use program requirements is the first step towards achieving compliance. Make preparation for a Meaningful Use audit part of the practice routine.