Meaningful Use Audit Support

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The Center for Medicare and Medicaid Services (CMS) has contracted with Figliozzi & Company, CPAs P.C.1 to conduct meaningful use audits of certified Electronic Health Record (EHR) technology as required in Section 13411 of the Health Information Technology for Economic and Clinical Health Act (HITECH Act), as included in Title XIII, Division A, Health Information Technology and in Title IV of Division B, Medicare and Medicaid Health Information Technology of the American Recovery and Reinvestment Act of 2009. The HITECH Act provides the Secretary, or any person or organization designated by the Secretary, the right to audit and inspect any books and records of any person or organization receiving an incentive payment.

Pre and Post Attestation Audits

Once a letter is sent to inform a practice or provider that it or he has been selected by CMS for an audit of its meaningful use of certified EHR technology for the attestation period attached to this letter is an information request list. This list may include specific meaningful use measures if it is a Post-audit. Be aware that this list may not be all-inclusive and that CMS may request additional information necessary to complete the audit.

When a provider or practice gets the letter indicating that he or it has been selected for an audit, he has two weeks to submit the documentation that is requested.

Meaningful Use Experts Audit Support

1. Once an audit is scheduled, a MUE can assist a practice with gathering all of the documentation to support attestation data for all meaningful use objectives and clinical quality measures claimed for attestation.
2. If documentation for any measure does not exist and the provider claims that the measure was met, A MUE can work with the EHR and provider to recover some of the data.
3. At times, the MUE will need to work with the EHR vendor on how to document measures that were met. This may require capturing screen shots in some cases.
4. In a post-audit case, the MUE may need to communicate directly with Figliozzi & Company to clarify the measures being audited.
5. Documentation to support payment calculations (such as cost report data) should follow the current documentation retention processes.
6. The MUE will walk through the attestation requirements or data used to attest with the provider to assure that all relevant documentation is gathered and stored for any future audit.
7. EPs, eligible hospitals, and CAHs should retain all relevant supporting documentation— Documentation to support attestation data for meaningful use objectives and clinical quality measures should be retained for six years post-attestation.
8. The MUE sends the data electronically to Figliozzi & Company.
9. If a provider wants to appeal the audit, the MUE can assist the provider through the appeal process and with gathering the documentation necessary to show compliance with the measures being audited. In some cases this may be caused by limitations in the vendor EHR.
10. Additional information may be needed during or after the initial review process.
11. The pre-payment audits will in some cases require an on-site review at the provider’s location and/or a demonstration of the EHR system.
12. The MUE assigned to the provider will be available until the entire audit has been completed and assist the practice however needed.
13. The cost for a Meaningful Use Audit Support is $750 for complete audit support.

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