In God we trust, all others, bring your data...
We have attested over 1000 physicians, of every speciality, and defended over one hundred providers in audits. At times we have had to run a manual
reconcilitation of the data, showing that the vendor dashboard was incorrect in their calculation of the data. We have represented providers who have been denied for Meaningful Use attestation , and
have sucessfully defended 100% of our audit appeals.
If anyone can help, we can!
Call or e mail the office today....you have only two weeks to respond, and it will take time to rebuild the file and submit a response.
If the government gives you
money, you can expect that it will look to audit your results. Since 2011, CMS has disbursed nearly $20 Billion under the Medicare and Medicaid Electronic Health Records (EHR) Incentive Programs, to
nearly half a million eligible professionals. It should come as no surprise that CMS now intends to audit at least 5% of Meaningful Use attesters. And the early results are not positive as nearly a
quarter of professionals audited to date have failed! The audits are required by the Health Information Technology for Economic and Clinical Health Act, which created the Meaningful Use Incentive
program and are conducted by the accounting firm of Figloiozzi and Company (See a sample audit letter
A failed audit likely means
refunding some or all of your incentive payments back to the government.
Post-payment audits by CMS began
in 2011 at the meaningful use program's beginning. In November 2012, the HHS Office of Inspector General published a report saying CMS was not doing enough to prevent improper payments and
recommending that CMS conduct pre-payment audits to verify attestation documents. Pre-payment audits began in 2013. Every provider who has accepted money from the EHR Incentive Programs is facing the
potential of a Meaningful Use audit.
CMS recently released statistics
on the volume of CMS Meaningful Use Audits conducted to date. The audit failures only report who failed an audit, not whether the failure was reversed on appeal.
10,000 unique audits were conducted on 265,075 attestations
4,601 have been completed
22.7% of EPs failed to meet meaningful use standards
98.9% of failing EPs did not meet appropriate measures and objectives
613 post-payment audits were initiated from 4,637 attestations
4.9% of EHs failed their audits
The average incentive returned was $1.1 M
Total incentive recoupment has totaled $33 M
A provider that fails just one
element of a Meaningful Use audit not only must return the entire incentive payment for that year, but also is automatically scheduled for another audit for another participating year. The most
common problems identified so far are noncompliance with a required data security risk assessment and a lack of adequate documentation to support some of the responses provided in the
Providers selected for the audits
have two weeks to submit their documentation.
Per CMS, the initial review
process will be conducted at the audit contractor’s location, using the information received as a result of the initial request letter. Additional information might be needed during or after this
initial review process, and in some cases an on-site review at the provider’s location could follow. A demonstration of the EHR system could be requested during the on-site review.
For more CMS guidance about
pre-payment and post-payment audits, please refer to the CMS EHR Incentive Programs Audits Overview.
So what can you do to prepare for
an audit? Attesting providers should not to rely on their EHR vendor’s certification, as providers are responsible for assuring and documenting Meaningful Use within their practice. Providers
also should maintain supporting documentation for six years (as that is the potential audit window), and make sure that the information is easy to retrieve, since the time limits for responding to
audit requests can be as short as 2 weeks. CMS has prepared advice for providers in preparing documentation in the event of an audit.