Meaningful Use Expert, Jim Tate, has a really interesting post up on his Meaningful Use Audits website that shares some of the details CMS offered on the EHR incentive audits and appeals process. I know many of my readers are worried about the meaningful use audits and are interested in these details.
You can go and read Jim’s full post for all the details, but I wanted to highlight a few of the items he mentions.
First, CMS said that 5-10% of providers will be subject to pre/post-payment EHR incentive audits. Jim calls this casting a “wide net” for the MU audits. Considering meaningful use stage 1, it makes some sense why the MU audit net would be cast wide. I’m sure many who read this have a friend who’s been through the audit.
I was really intrigued that CMS said “If a provider continues to exhibit suspicious/anomalous data, could be subject to successive audits.” This reminded me of something my brother said about the military. He said that if you got your uniform inspection right the first couple times, then the officers would stop looking at you quite as much. However, if you had something wrong at first, be ready to be scrutinized. It seems like CMS is taking a similar approach. As in most things in life, it’s just better to be honest and accurate. Then, you don’t have to look over your shoulder.
Jim also notes that CMS said that no risk profile will be made public. Basically, we aren’t going to get any clue into how they chose who to audit. Plus, Jim notes that the only next step if you fail an meaningful use audit is to file an appeal.
As long as we have meaningful use tied to EHR incentive money and payment adjustments, I don’t see these MU audits going anywhere. So, if you’re attesting to meaningful use, make sure you’re prepared for an MU audit if it comes.