If you work in Healthcare, you know the feeling. The sun is shining, the servers are humming, and your projects seem to be progressing surprisingly well on this particular day and then…
“Dear EHR Administrator:
You have been selected by CMS for a HITECH EHR Meaningful Use Audit for payment year 1. We are the CMS Contractor authorized to perform the audit. Please see the attached documents and submit all requested information by 6/17/2014. Please confirm your receipt of this e-mail. Also, please confirm whether you will be the contact person for this audit. If you will be the contact person, please supply your preferred contact information for future correspondence. If you are not the contact person for this audit, please advise us who at your facility is the correct contact person and furnish their e-mail address. The auditor assigned to this audit is (REDACTED). You may contact her with any questions. She can be reached via email at (REDACTED)@cms.hhs.gov.
Peter J. Figliozzi, CPA, CFF, FCPA “
For all of you participating in Meaningful Use, you probably appreciate that the stakes are high. If you’re a hospital getting audited under Stage 1, your agency may well have received hundreds of thousands of dollars under the program. If you’re a dual Eligible Hospital participating under Medicaid and Medicare and also have outpatient Eligible Professionals, that number is more likely in the Millions. Many Millions. And guess what happens if you don’t pass? According to those who have paid a little less attention to the regulations than they should have, it sounds like this…“Please return in full the overpaid amount to us by XX/XX/XXXX and no interest charge will be assessed……..If you do not refund in full within 30 days: In accordance with 42 CFR 405.378 simple interest at the rate of 10.125% will be charged on the unpaid balance of the overpayment beginning on the 31st day. If your debt reaches 61 days delinquent you debt will be referred to the Department of Treasury’s Debt Collection Center (DCC) for Cross Servicing and Offset of Federal Payments.”And it’s an all or none proposition. There is no such thing as an almost pass. Forgot to do a security audit BEFORE your attested? Fail. Forgot to implement a system that was a Complete Certified EHR? Fail. Forgot to ERX, CPOE, or collect allergy data? You get the idea. There is no almost passed.
But fortunately for both Xpio Health and our client, things went quite well. Privacy and Security Analysis? Check. Numerator and Denominator Reports? Check. Screen shots, workflows, evidence of utilization, dates of implementation, and EHR certification version numbers in sync? Check. All documents neatly stored on the Xpio Health MUCP audit portal within reach of all on the MU team? Actually, yes.
Dear EHR Admin,
We have completed our audit of how YOUR AGENCY demonstrated meaningful use of certified Electronic Health Record (EHR) technology in accordance with 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 organization eligible to receive an incentive payment.
We performed a review of your facility’s meaningful use attestation for the Program Year 2013 and Payment Year 1. Based on our review of the supporting documentation furnished by the facility, we have determined that YOUR AGENCY has met the meaningful use criteria.
Please also note that this audit does not preclude YOUR AGENCY from future, prior or subsequent year audits.
Peter Figliozzi, CPA, CFF, FCPA
We all appreciate that auditing is a part of life as a healthcare professional. It’s a part of building integrity and trust into the healthcare system. If you do your job well, keep your documents organized, and don’t cut corners, the result is one that everyone will appreciate – long after the money is gone.