How to Prepare for and Manage a Meaningful Use Audit
The Meaningful Use program audits first started in 2011 when post-payment audits began being conducted. By the end of 2012, the Department of Health and Human Services (HHS) suggested that Centers for Medicaid and Medicare Services (CMS) initiate prepayment audits to scrutinize attestation documents. The HHS report stated that the CMS would oversee approximately $6.6 billion in incentive payments to be paid between the years of 2011 to 2016.
Because of this initiation, healthcare practices must now assume that at some point a Meaningful Use (MU) audit will occur. CMS does not disclose how many audits have already been conducted. However, since the Meaningful Use audit program was enacted, providers say they believe more Medicaid-incentive audits are happening in each state.
Preparing your medical practice for a Meaningful Use compliance audit is much easier with some preparation and planning throughout the year. The following are suggestions for handling a meaningful use audit:
1. Plan for the audit
Members of the team should be advised about document retention as a best practice. The practice administrator should prepare and share a list of these documents for the team’s use. The practice should perform regular pre-audits in preparation for an actual one. Physician practices are chosen at random, so there is no way to assess the probability of an audit.
Verifying that the practice meets specific targets of the Meaningful Use program is critical. The practice should maintain registration-attestation process records and documents for a minimum of six years.
2. Audit compliance
Determining audit compliance involves many tasks. For instance:
- Respond promptly to the audit letter. After receipt, the provider has up to 14 days to acknowledge the audit notice.
- Those involved in the audit should stay calm when meeting with auditors. Practice members should proceed in the belief that CMS wants to pay to encourage the use of EHR systems.
- Providers should allow the internal audit team to manage the process. For instance, physicians should not discuss any part of their process with auditors and assume the verbal exchange is adequate to the task. Requested information must be exchanged in the mode and manner required. Screen shots are an acceptable way to show auditors that certain steps were performed (without sharing protected health information).
3. Error Avoidance
Auditors are searching for discrepancies between what the provider submitted in the attestation and what was actually performed. Smaller practices might not have a dedicated administrative team to shoulder the needs of a Meaningful Use audit. The practice manager might not have the necessary skills to properly prepare for an audit. In this instance, physicians should step in to supervise or take charge of the audit preparation to ensure they are able to pass the audit successfully.