The Audits are Here
I have noticed over the past few weeks, my clients are starting to contact me in regards to their security risk assessments. They are being audited by CMS. I really thought this was not going to hit for a while, but I am seeing it more and more. It is actually happening. The audits are here! The audit request will come in the form of a letter. It will say:
This letter is to inform you that your organization has been selected by the CMS for an audit of your facility’s meaningful use of certified EHR technology for the attestation period. Attached to this letter is an information request list. Be aware that this list may not be all-inclusive and that we may request additional information necessary to complete the audit.”
If you have attested to meaningful use, and have not had a security risk assessment, you need to have one done…now. It is not expensive, and easy to do. If you have had one, make sure you can produce a document with all the physical, technical and administrative requirements met. You will also need to make sure you have proof of a certified EMR, and that you are entering at least 50% of your patients into that certified EMR.
Basically what is being requested is documented proof of everything you claimed when you applied for the CMS EHR incentives. I hope you have a folder in the bottom of a drawer somewhere that has all the required information you are going to need. Hopefully you are able to produce from your EHR a report that details the numerators and denominators for each percentage based measure during the reportable period you claimed. This will be compared with data the auditor has from your initial online attestation. If you numbers do not match you will have some explaining to do. There are some legitimate reasons the numbers might not match. I’m just hoping for the provider’s sake that careful attention and due diligence was applied during the documentation of meaningful use and subsequent attestation.
Get all your ducks in a row BEFORE you get a letter in the mail from Figliozzi & Company. The meaningful use audits are real! You certainly don’t want to give that money back!