Surviving a Meaningful Use Audit

This is a New Jersey based medical group.

THE RULE

Under the Meaningful Use program, CMS (Centers for Medicare and Medicaid Services), an agency within the Unites States Federal Government, provides financial incentives to eligible professionals and hospitals for adopting certified electronic health record (EHR) system and demonstrating EHR usage in accordance to the standards specified by the government.

PROBLEM

We were working with New Jersey based medical group, helping them demonstrate Meaningful Use compliance. CMS randomly selected a physician from the group for an audit and appointed a CMS affiliated contract auditor to review the case. Failure to comply would result in loss of incentive payment for the physician and a high probability of the entire group being audited for the subsequent years. The auditor requests system usage logs, EHR reports, and email exchanges with third party vendors such as the state Immunization Information Systems (IIS) to ensure compliance.

PROCESS

The auditor scrutinizes each measure under the Meaningful Use program and requests specific documentation that demonstrates compliance. The group administrator approached our compliance team to assist them with the audit process. We initiated the process by verifying group and EHR vendor privacy and security documentation to build a strong case. Working with the EHR vendor proved to be a major bottleneck due to unavailability of consistent support and the complex nature of the software itself. We educated the medical group on the audit process and continuously followed up with the IT consulting agency employed by the group and the EHR vendor, for gathering compliance documentation.

RESULTS

The auditing agency passed all measures, except one, due to insufficient EHR information. We appealed directly to CMS to reconsider the application. Upon thorough review, CMS upheld auditor’s decision and the physician is now being considered for successfully demonstrating Meaningful Use compliance and financial incentives.