Marc Grossman, Principal, and Jenna Barsky, Senior Consultant, WeiserMazars

Meaningful Use (MU) is becoming more challenging and expensive for both providers and the federal government. Centers for Medicare and Medicaid Services (CMS) payouts rose dramatically from $5 billion in June 2012 to $26 billion as of September 2014, which has led to a heightened focus on MU audits and a significant surge in the total number performed in 2014. This intensified regulatory environment is causing healthcare providers to question the certainty of incentive payments. Preparing for a potential audit is crucial in this all-or-nothing program, where MU documentation shortfalls can lead to big losses. The time to secure past and future incentive payments is now.

The increased number and stringency of MU audits has occurred primarily as a result of political pressure to make every MU dollar count. The last Government Accountability Office (GAO) review of the MU audit strategy resulted in the institution of pre-payment audits, which gives CMS the option to withhold payment until an organization successfully fulfills an audit request. The next review could tighten the purse strings even more by strengthening audit tactics.

CMS has designated Figliozzi and Company to perform audits on at least 20 percent of MU attestations, evenly split between pre-payment and post-payment audits. Medicaid providers could also face an additional audit performed by their state’s Medicaid program.

While there is not a published list of audited providers, word is spreading quickly through the healthcare community of eligible hospitals and professionals who have received the dreaded audit notifications.  An increasing number of providers are appealing negative audit outcomes, while some have voluntarily returned incentive payments in order to avoid claims of fraud. Two of these providers are Health Management Associates, which is in the process of repaying $31 million, and Habersham Medical, which must repay $1.5 million in incentive payments.

Although CMS’ audit selection method is undefined, providers should be careful to avoid attestation red flags and documentation pitfalls that could trigger an audit. An audit can occur up to six years following each MU attestation, increasing the need to maintain the appropriate documentation.

The most common types of MU documentation are:

  • Proof of complete ONC certification; 
  • Core and Menu Measure reports; 
  • Clinical Quality Measure reports; 
  • Screenshots as evidence of compliance throughout the reporting period;
  • Evidence of compliance for Yes/No objectives; and  
  • Policies or procedures. 

Key lessons learned thus far

As MU audits become increasingly common, certain best practices are identifiable:

  • Have a designated MU Coordinator; 
  • Prepare for an audit prior to attesting;
  • Document and save everything; 
  • Create an electronic “audit folder”;
  • Print reports on day of attestation;
  • Do not rely heavily on software vendors for proof of compliance;
  • Pay attention to details; 
  • Only provide requested documentation; and 
  • Ask questions.

We have seen the value of these practices in numerous instances, ranging from small physician practices to large academic medical centers. The underlying success factor of each organization is the formation of an audit strategy prior to the reporting period. In one instance, a hospital selected a staff member to take on the role of “MU Audit Coordinator” to collect documentation throughout the reporting period and organize the information in electronic folders. Prior to the start of each month in the reporting period, the Coordinator sent out a list of needed documentation to the MU team, indicating the individual responsible for submitting each piece of information. After submission to the Coordinator, the organization had a third-party MU expert review the documentation for completeness. The Coordinator also confirmed the email address listed in the MU registration to receive the audit notification and ensured the account was frequently monitored.

Soon after the organization attested to MU, the Coordinator received notification of a pre-payment audit. Each information request was satisfied by selecting the appropriate documentation from the prepared electronic folders. The Coordinator also contacted the Auditor prior to submitting the documentation to ask questions and confirm the documentation fulfilled the Auditor’s request. Ultimately, the hospital’s diligence paid off, resulting in a swift decision that the hospital was in compliance with Meaningful Use.

With the new measurement period about to start, we recommend that hospitals review their documentation process and make sure that they are being thorough and timely in their approach to gathering appropriate documentation to substantiate compliance from the very beginning (October 1). Being unprepared for an MU audit is taking an unacceptable risk with an organization’s financial health, particularly in this increasingly stringent atmosphere of program review.

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