Meaningful Use Audits Are Coming: Is Your Organization Ready?

Ilona Davis, Risk & Business Advisory Principal
October 2015

The Centers for Medicare and Medicaid Services (CMS) has required recipient hospitals of Meaningful Use (MU) incentives to be subject to audit as part of the new, evolving program. When those audits take place at your hospital isn’t a matter of if, but likely rather when. Are you ready?  If not, you should be, because the process of auditing organizations like yours has already begun.

Audits for organizations receiving Federal funding are not a new concept, but they require time and can drain away vital resources from the scope of personalized patient care. No one wants to be audited, and everyone can appreciate the time and resource distraction any audit can cause. Failing the audit process, however, can result in further detriment to your organization. An organization is susceptible to losing funding across multiple years, and sanctions can and will be imposed for organizations that have attested to a set of objectives that cannot be audited. In today’s healthcare industry, a loss of revenue is not an option.

Sometime in the coming months, your organization could very well receive notification from an audit firm engaged by CMS for Meaningful Use. That notice will trigger a process that will give your organization as little as two weeks to verify its original attestation. With multiple electronic health records, verification of hospital and physician level attestations and multiple audit periods, two weeks is unlikely enough time to start preparing your audit documentation from scratch and deliver it on time. When that happens, what then?

The answer is as simple as preparing now. While you can’t be sure which period your organization’s audit will cover, you can appoint an execution team, design your response process, verify reporting capabilities and prepare to support your organization’s submitted attestation.  Organizations can even take the step of conducting a mock audit or internal audit to further verify their preparedness. The approach, when measured and resourced appropriately, will assure a documentation trail and will prepare your internal resources of what is to be expected when the real audit has commenced. Most importantly, performing an internal audit today will assure your team and organization that what was attested is in fact auditable.

There are seven key milestones in the Meaningful Use audit process.

  1. Six Years – MU audits can be performed for up to six years after the attestation. It’s crucial to document your response process and retain your verification documentation so it’s assessable in the future. Due to the value of what is at stake, we recommend three backups; a hard copy, on a CD in a lockbox, and electronic copies on secure servers.
  2. Two Weeks – You will have as little as two weeks to submit audit documentation. Valid reasons for delays are very limited and do not include staffing issues, provider delays or financial issues. It is best to assume that no reason is valid. Missing the submission deadline can be counted as failing the audit.
  3. Incentive Payments – Which menu set objectives did your hospital select and which program were the incentives paid, e.g. Medicaid, Medicare, as a Critical Access Hospital? The incentive payment program will dictate what financial records you may need to gather in the event of an audit.
  4. Period and Stage – When were your incentive payments received and for which measures and for which MU Stage? This will dictate how far back you must be prepared to provide documentation and for which period and Stage each measure must be validated.
  5. Segregation – Keep documentation for each attestation and reporting period separate as they will need to be submitted separately.
  6. Mock Audit – If you have yet to be audited after your processes are in place, you should test them. A third party or internal team can conduct a structured audit following the CMS’s process.
  7. Appeals – Hospitals or Physicians that fail their MU audit have only one chance to appeal, but unfortunately there is little documentation about the appeal process. Many have described the process as a “Black Box” full of technicalities designed to derail the applicant. As the initial MU audit’s expectations are well documented, organizations should allocate the resources necessary to ensure this first submission will be successful.

The best approach to an MU audit is best practices. Managing the process not as a chore, or in anxious chaos, but by approaching it as any other high-value, high-visibility project will help guarantee success, both in time and resource engagement.

Notices of audits have already been distributed, and it’s likely many of your peers have already been notified. It’s important to start preparing as soon as possible so your organization has the best chance of successfully clearing this critical requirement. Appointing a leader for your audit preparation now, to allow planning time to position your execution team for success, is the best first step an organization can take. It’s also practical. Successful audits are achieved by solid, practical preparation.

Your hospital or healthcare organization may benefit from outside expertise and the experience a professional services practice can offer. We can help. We have an approach and methodology to get your organization prepared. Reach out to Baker Newman Noyes’ Risk and Business Advisory team to learn how we can help you during this process. For more information and help in preparing for your Meaningful Use audit, contact Ilona Davis.