By: Gena Fouke, Director of Meaningful Use
Be aware, CMS has significantly increased the number of Meaningful Use Audits, jeopardizing your organization’s meaningful use dollars. Any eligible hospital or eligible professional attesting to receive an EHR incentive payment for either the Medicare EHR Incentive Program or the Medicaid EHR Incentive Program is subject to an audit.
There is no all-inclusive list of supporting documents, as the level of the audit review may depend on a number of factors. However, CMS clearly states that the primary documentation that will be requested in all reviews is the source documents that the provider used when completing the attestation.
CMS has recently released hard data that reveals the volume of CMS Meaningful Use Audits conducted to date. The audit failures only tells us who failed an audit, not who had that failure reversed by appeal, or ultimately had their incentives recouped. The data reflects Medicare EP’s and Medicare/Medicaid (dually-eligible EH’s) audits. The audit data is based on unique audits, not providers.
CMS MU Audit Data:
613 post-payment audits were initiated from a total of 4,637 attestations
4.9% EH’s failed the post-payment audit
The average incentive returned was over $1.1M
- Incentives recouped by CMS following post-payment audits total over $33M
10,000 unique audits were conducted from a total of 265,075 attestations
4,601 have been completed
22.7% of EP’s failed to meet meaningful use standards
- 98.9% of EP’s that failed their audits did not meet the appropriate objectives and measures
These numbers are going to continue to increase as more Eligible Hospitals and Eligible Professionals continue to be audited for Stage 1 and Stage 2 attestations. Many hospitals and providers are very frustrated that the final rule released in September 2014, did not ease the reporting timelines and Stage 2 attestation requirements.
Smaller hospitals and provider practices are at higher risk for failing an audit because they often do not have staff with expertise on meaningful use, regulatory issues, HIPAA security or the audit process.
The best way to avoid a failed audit is be prepared. Conducting a mock audit will increase the chance of a successful outcome should you be flagged for an audit.