CMS has been auditing Meaningful Use payments since 2012, and since that time, we’ve been helping our customers through the process. Our experience has proven time and time again, the better a site prepares now, the more likely it is that the site will pass. This includes tracking of how they met their reporting measures and which supporting documents are to be provided to the auditor.
With CMS now auditing about 20% of all providers each year, it's no longer “if” you'll be audited, but “when.” In the last four months, Iatric Systems has assisted 7 hospitals with their Stage 1 and Stage 2 audits. What has astonished me the most, is that the auditors are not aware of many of the new MU rules, FAQs, or changes in the program, such as the Flex Rule. Most of the hospitals we assisted received multiple requests for additional information from our friends at Figliozzi. Even after supplying proof for how they handled a measure, the auditor kept asking additional questions. We learned quickly that in instances where the auditors were unaware of MU changes, the responsibility to educate the auditors rests solely on the hospital.
Here are some specific examples of how we've helped hospitals with attestation:
- One hospital, which stood to repay $4.5M for a single reporting period, included a response email from ONC on how they addressed a Stage 1 MU issue. Despite the letter as proof, the auditor still asked more questions.
- For another hospital, the auditor was not happy with the third-party vendor’s Transition of Care receipt report, asked for proof that the vendor was certified, and wanted the vendor to explain their report. We assisted the hospital in educating the auditor about TOC, and that the vendor was not required to be certified.
If your site hasn’t been audited, now is the time to ask yourself: “What could an audit failure mean to our facility? Layoffs? Loss of creditability with CMS?”
As a reminder, if you fail the audit, MU re-payment is due within 60 days and you will be audited in following reporting years. For more information, see the Audit Overview factsheet from CMS. Meaningful Use audits no longer simply require proof of the Numerator and Denominator measures, but your site must now stand firm with all your supporting documents, including any proof from CMS or ONC.
Remember that the window for an audit is six years from the date of attestation. Will the person that attested still be employed at the hospital to respond to an audit? Did you just attest for 2015 or wonder if your current proof for this or any other reporting years would satisfy an auditor?
One way to sleep easier is to contact our Meaningful Use team and schedule a Mock Audit. Believe me, the cost for a Mock Audit is much less of a financial impact as compared to repaying the incentive money. Let our team assist you, so that you too can receive that golden ticket email, in which the subject line states “Meaning Use Audit Determination Letter,” and the result is a pass.
Looking for more information on the Meaningful Use audit process? Watch our recorded educational Webcast: How to Prepare for a Successful Meaningful Use Audit: