Meaningful Use Audits: 4 Ways to Prepare and Survive

Medical practices across the country are successfully attesting to the government's requirements for meaningfully using an EHR. But some are learning that there's one more major hurdle they need to pass through before enjoying the fruits of their labor.

"Any provider that participates in the incentive program and receives money could be subjected to an audit," said Amy Thorpe managing consultant at healthcare IT consultancy Encore Health Resources, during her presentation "Don't Panic! Surviving a Meaningful Use Audit," part of this year's Healthcare Information and Management Systems Society (HIMSS) Conference in Orlando, Fla.

While the prospect of a meaningful use audit is nerve wracking (after all, failure could result in paying back the incentive monies you earned), gaining peace of mind that your practice is prepared for a potential audit should not be too difficult, said Thorpe. "There are ways that you can minimize the impact of an audit and it's pretty basic stuff."

Thorpe shared several ways practices can prepare for audits, including:
1. Have a defined procedure in place to manage the audit process. Determine who in your organization will receive notice of an audit, and make sure that they will recognize that it is an audit request, said Thorpe.

2. Make sure that you can produce documentation quickly. Once your practice receives an audit notification, it will have two weeks to get the information that is requested by the auditor assembled, said Thorpe, noting that information typically needs to be e-mailed in a PDF or uploaded to the auditor's portal.

3. Assemble information. Assemble documentation that could be requested during in an audit and store it adequately, said Thorpe, noting that you could be audited for up to six years post-attestation. "This is not a particularly difficult prospect for the first year [of program participation], perhaps, but as we look at out over five or six years as things are upgraded and new versions come out, to be able to maintain that install log, that audit trail, really is important." she said.

4. Conduct a self assessment. Assess whether your practice is truly prepared for a potential audit by conducting a self assessment, said Thorpe. Here are a few of the questions she recommended practices consider during this self assessment:  
• Are you keeping all of the source documents that you used during attestation?
• Have you thought about how you are going to store that evidence for six years?
• Do you have a robust system that would enable someone to find these documents five years from now?
• Can these documents be retrieved easily?
• Has your organization developed a clear vision of how it will respond to a CMS audit?
• Do you have all of the people that would need to participate identified?
• Do they understand their roles and responsibilities?
• Have you held a mock audit and was staff able to produce the information in a timely manner?

"If you pay attention to these kinds of things and do a little planning up front ... you will probably be very successful," said Thorpe. 

Has your practice experienced a meaningful use audit? Share your experience, and any lessons learned, in the comments section.